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Year end AUM broken out by discretionary and non-discretionary assets should be confirmed – Do not include broker dealer assets if your firm is a hybrid – RIA & BD. The regulators do not look kindly on this especially if the additional assets move your firm from state to SEC

Red Flags 2014 BD and RIA hot topics. Regulators continue to amend and draft new regulations as they proceed to implement the JOBS Act, Dodd-Frank and consolidate the NASD/NYSE Rule books. The focus for this event is on the M&A Brokers No Action letter, Crowdfunding, Cyber security and Structuring a

Have you read through the FINRA Monthly & Quarterly Disciplinary Actions lately? My question is this: was the NASD just out of touch seven plus years ago, or were the exams just a routine ‘check the box’? Many of these compliance infractions should have been obvious to an examiner –

Beginning in Q3, the CEO and CCO(s) will receive the all-encompassing manifest of reports provided to you by your carrying firm(s).  This package of reports will outline ALL the reports available to your firm as well as a list of the reports you have requested. The report listing already provided

Earlier this month, Commissioner Kara M. Stein reinforced very clearly the importance of compliance. From her stand point, being compliant is far more complex than just following the rules and checking boxes. Every person in financial services, at any level, has a responsibility to “do the right thing” and report when it is

Are the SEC and FINRA articulating their message of compliance requirements clearly? Has the volume become overwhelming? What do you think? The regulators are aggressively pursuing their agenda with broker-dealers and registered investment advisor firms like never before and ‘bad actors”’ will be punished severely. What do they mean by,

This might seem intuitive, but is not always the case. Depending upon your investment management division’s interaction with the compliance team, responsibilities may only be published in a compliance manual and sitting on a shelf. In many cases not only was it not read, but may not even be locatable.

Compliance is considered a cost center by most; the more enlightened will view it as a form of insurance, protecting their financial standing and maybe even more importantly their personal and business reputation. Knowing your risk exposure will help you understand your potential liability as an enterprise. Business risks come

If your firm, staff or Advisors have been affected by any of the storms this year, this may be an opportune time to document the events your firm is experiencing and satisfy 4370(b). There has rarely been a better time to test and document your Business Continuity Plan (BCP) procedures