The June 30th compliance deadline for Regulation Best Interest and Form CRS is quickly approaching. It presents new compliance requirements for broker-dealers and investment advisers engaging in a retail business.
Your firm is beginning to get in the groove since the shelter-in-place orders have been implemented. In the past, you have worked from home on certain days, but the transition to full-time teleworking, homeschooling, and pet sitting has been a challenging reality. Then surprise! You get a call from your regulatory coordinator that FINRA or the SEC has decided to conduct a regulatory exam of your firm starting now.
Beginning in 2017, the United States Security and Exchange Commission (“SEC”) initiated a series of examinations aimed at compliance policies and procedures regarding individuals within these firms that had a prior disciplinary history.
The SEC’s Office of Compliance Inspections and Examinations (OCIE) recently published a Risk Alert pertaining to “WannaCry,” the ransomware worm that infected hundreds of thousands of computers in over 150 nations earlier in May, 2017. WannaCry infects computers with malicious software that encrypts users’ files and demands payment to regain access to the data. The alert provides cybersecurity best practices, including a new initiative towards “rapid response” methods that firms should use to respond to cybersecurity challenges. It also describes factors that firms may consider to (1) assess their supervisory, compliance and/or other risk management systems related to cybersecurity risks, and (2) make any changes, as may be appropriate, to address or strengthen such systems. Read More…