Archive for the Uncategorized Category

FINRA is playing it close to the vest, giving you until February 21 for input on its concept to develop a new oversight system – Comprehensive Automated Risk Data System (CARDS). Regulatory Notice 13-42 outlines the purpose of this new technology. Some may look at this initiative as completely intrusive

A very busy time of year indeed; nevertheless, we need it all and then some. Just as every day is a new day, every year brings new challenges. Most companies close the books and tasks on a calendar year-end basis. If your firm is one of them, it’s time to

November 20, 2013 is the day the SEC Red Flags rule becomes effective. Does your firm fall under the definition of firms required to adopt these rules? Is your Identity Theft Red Flags rule procedures documented? Do your procedures meet all the requirements? Do your procedures include, at a minimum

FINRA will file with the SEC a proposed rule change regarding recruiting bonuses paid to Registered Representatives for moving from one broker-dealer to another. There are two mechanisms to the proposal; disclosure and reporting to FINRA. The disclosure to customers is designed to assist them in making a decision whether

We are all aware that the purpose of FINRA’s Broker Check was to give both the public and financial services firms the ability to view both broker-dealers’ and registered representatives’ status with FINRA. The report briefly discussed the profile of the firm or individual and also identified any disciplinary events.

FINRA recently announced a new exam program and data collection technology.  The new program is now being based off your firm’s risk as defined by FINRA. FINRA has many data collection points – Form BD, Form BR, U-4/U-5 filings, FOCUS reports, SSOI filings, OATS, TRACE… the list goes on. The

Trade Desk Supervisors and Chief Compliance Officers are required to establish, maintain, implement and monitor the firm’s supervisory procedures for trading, whether proprietary or in customer accounts. In some instances, the trading function of the firm is where revenue is generated and profits are made. Your procedures should address the

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.

At a recent SIFMA conference earlier this month, the SEC co-Director of Enforcement Andrew Ceresney discussed the SEC exam and review priorities for 2013. The overall theme is his team intends to be both vigilant and proactive in identifying and reacting to a firm’s compliance deficiencies. Mr. Ceresney commented that

FINRA and the SEC have sanctioned many firms and individuals for not establishing or following their AML Compliance Program. The NASD NtM 02-21 provides guidance for member firms to build their program. The findings have ranged from not having adequate safeguards based on the firm’s business model to “willful blindness”.