Regulatory Notice 22-18: Forgery and Falsification

Regulatory Notice 22-18: Forgery and Falsification

Regulatory Notice 22-18Ā  reminds firms of their rule obligation related to forgery and falsification of records and provides Firmā€™s with some specific examples that they have encountered from other Firms. These examples are great tools to review against your program and audit to ensure that your Firm is meeting rule requirements. What is Forgery or Falsification of a Record? Forgery occurs when one person signs or affixes, or causes to be signed or affixed, another personā€™s name or initials on a document without the other personā€™s prior permission. Falsification occurs when a person creates a document or entry in a Read more about Regulatory Notice 22-18: Forgery and Falsification[…]

Merrill Mutual Fund Enforcement Lessons Learned

Merrill Mutual Fund Enforcement Lessons Learned

FINRA (Financial Industry Regulatory Authority) announced on June 2, 2022 that it ordered Merrill Lynch, Pierce, Fenner & Smith, Inc., to pay 15.2 million in restitution and interest to thousands of customers who purchased Class C mutual fund shares when Class A shares were available at a substantially lower cost. FINRA news releases are useful tools to look for trends in violations and other sanctions. These trends can assist you in identifying weak areas in your Firmā€™s compliance programs or surveillance. Below is a summary of the Merrill order, as well as key takeaways. Click here for the corresponding news Read more about Merrill Mutual Fund Enforcement Lessons Learned[…]

Form U4 Disclosure Reporting Best Practices to Protect You and Your Firm

Form U4 Disclosure Reporting Best Practices to Protect You and Your Firm

The U4, also known as the Uniform Application for Securities Industry Registration or Transfer, is the primary source of information for a registered representativeā€™s (also known as ā€œbrokerā€, ā€œfinancial professionalā€, ā€œfinancial advisorsā€) Central Registration Depository (CRD) or Investment Adviser Registration Depository (IARD) record. Both the firm and the registered representative can update Form U4, but it is ultimately the registered representativeā€™s responsibility to make sure Form U4 is accurate and current. The U4 record, contains personally identifiable information about each applicant such as name, SSN, physical characteristics, address history, work experience, and education. In addition, the U4 also requires disclosure Read more about Form U4 Disclosure Reporting Best Practices to Protect You and Your Firm[…]