Form CRS Observations

Form CRS Observations

Broker dealers, specifically the Chief Compliance Officer (“CCO”), are required to review their firm’s compliance programs and procedures at least annually to ensure that all compliance areas are working in accordance with the rules and regulations set forth by the Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”). Per the Securities Exchange Act of 1934 under rule 17a-14, one area of review for broker dealers who maintain retail clients is Form CRS, the customer relationship summary. Form CRS contains various information regarding the broker dealer that is important for retail clients to know. Over the past Read more about Form CRS Observations[…]

FINRA Unscripted Podcast: Regulation Best Interest and Form CRS Two Years In

FINRA Unscripted Podcast: Regulation Best Interest and Form CRS Two Years In

FINRA recently released a podcast Regulation Best Interest and Form CRS: Two Years In. This podcast provides a great update on the current Regulation Best Interest and Form CRS trends and best practices as well as common problem areas and effective practices to compliance. A few highlights from the podcast: Regulation Best Interest vs. Form CRS Reg BI applies to any retail firm or any firm with retail customers where recommendations are being made whereas Form CRS applies to any Firm that has retail investors including Firms that offer solely self-directed business. The podcast notes that there is no de Read more about FINRA Unscripted Podcast: Regulation Best Interest and Form CRS Two Years In[…]

FINRA’s Top Priorities for 2022

FINRA’s Top Priorities for 2022

Early in the year, FINRA released their 2022 Report on FINRA’s Examination and Risk Monitoring Program, which is designed to inform member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations. In this report detailing FINRA’s top priorities for 2022, FINRA addresses 21 regulatory areas which are grouped into 4 categories: (1) Firm Operations, (2) Communications and Sales, (3) Market Integrity, and (4) Financial Management. From these 21 regulatory areas, FINRA highlights 7 that they feel are the most important and affect a large portion of member firms, which are as follows: Reg BI and Form CRS Read more about FINRA’s Top Priorities for 2022[…]

Form ADV

Form ADV

Form ADV is the uniform form used by investment advisers that manage at least $25 million in assets to register with both the SEC and state securities authorities. The Form ADV is divided into 3 parts. Part 1 is a fill-in-the blank form that contains information about the investment advisory business and how it operates. Part 2 is a brochure in narrative form that include plain English disclosures of the adviser’s business practices, fees, conflicts of interest, and disciplinary information. The last part is Part 3, which contains the relationship summary, which investment advisers are required to deliver to retail investors that discloses certain information about the firm.

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FINRA’s Top Priorities for 2021

FINRA’s Top Priorities for 2021

Early in the year, FINRA released their 2021 Report on FINRA’s Examination and Risk Monitoring Program, which is designed to inform member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations.

In this report detailing FINRA’s top priorities for 2021, FINRA addresses 18 regulatory areas which are grouped into 4 categories: (1) Firm Operations, (2) Communications and Sales, (3) Market Integrity, and (4) Financial Management. From these 18 regulatory areas, FINRA highlights 6 that they feel are the most important and affect a large portion of member firms, which are as follows:

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Form CRS Updates in 2020 (Part 2)

Updates to Form CRS in 2020 (Part 2)

The SEC released updates to Form CRS in 2020 with additions to their Form CRS FAQ, this time focusing on the Disciplinary History section. After so many updates, it is a good idea to go back through to refresh your memory.

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