BCP

BCP and COVID-19: Considerations for Firms

Many financial service firms have written supervisory procedures in place for business continuity planning (BCP). Tucked somewhere on a server or in a binder, many plans have been collecting dust. More than likely, these plans are only taken out during regulatory exams, branch audits, or internal testing. However, the current reality of COVID-19 (Coronavirus) has Read more about BCP and COVID-19: Considerations for Firms[…]

Examinations and Risk Monitoring

Examination and Risk Monitoring: What to Expect in 2020

FINRA recently released a podcast called “What to Expect: The 2020 Exam and Risk Monitoring Program“. It provides a wealth of information from three members of the Member Supervision Senior Leadership on what to expect from the Examination and Risk Monitoring program in 2020. Here are a few highlights from the podcast. Read More…

Annual Compliance Meeting

Annual Compliance Meeting: A Retrospective Review

FINRA initiated a retrospective review of the annual compliance meeting (“ACM”) requirement in April 2018. The findings were published on October 18, 2019 in FINRA Regulatory Notice 19-34Although the final assessment indicates that they are determined to maintain the ACM requirement without change, the Notice did provide additional guidance on fulfilling the requirements.

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FINRA Disciplinary Actions

FINRA Disciplinary Actions from January 2020

The Monthly Disciplinary and Other FINRA Actions report from January may provide a glimpse into the conduct by Firms and individuals that result in disciplinary proceedings. For Firms, a failure to evolve a program can be costly. For individuals, failure to disclose despite Firm-acknowledged requests may result in FINRA sanctions.

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annual training

Annual Training Considerations for Broker/Dealers

It’s 2020 and as the new year rolls in, so does annual training planning. Rule 3110(a)(7) requires each Registered Person to participate, at least annually, in an interview or meeting which discusses compliance matters relevant to their activities. Read More…

Electronic Storage Media

Electronic Storage Requirements: Is Your Firm Ready to Go Paperless?

Is your small broker-dealer drowning in boxes and boxes of paper? Do you cringe every time you think of storing yet another 50+ page document? Are you interested in exploring the benefits of cloud-based storage? If you answered “yes” to any of these questions, you must first consider your firm’s regulatory requirements for electronic storage media.

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Digital Communication

Digital Communications: 2019 FINRA Report

In the recent “2019 Report on FINRA Examination Findings and Observations,” one of the topics highlighted was the use of digital communications. This can include a wide range of social media, email, text messaging, and various other digital tools. The regulatory requirements pertaining to the usage of digital communications are outlined in Exchange Act Rule 17a-3 and 17a-4 and FINRA Rules 3110(b)(4) and 4510. These rules require procedures pertaining to the usage of these types of communications, as well as the appropriate maintenance of the communications in the form of books and records.

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Senior Investors: Protecting the Client

Today, investment advisers and broker-dealers face many challenges when providing advice to and working for senior investors. Many seniors are living with or approaching diminished capacity due to Alzheimer’s, dementia, and/or other health-related issues. Unfortunately, these health issues create vulnerability for financial exploitation from caregivers, family members, neighbors, friends, medical professionals, lawyers, clergy, bank employees, or financial service professionals.

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