On June 21 of this year, FINRA filed with the SEC proposed rule changes regarding supervision. Rules 3010, with a couple of exceptions, and 3012 respectively will be replaced by 3110 (Supervision) and 3120 (Supervisory Control System). There are a number of rules coming from this change such as 3170 (Tape Recording of Registered Persons by Certain Firms) and 3150 (Holding of Customer Mail).
If you are a ‘Rules’ junkie you know how confusing this can be. For instance, Rule 3110 was replaced by Rule 4510 and Rule 3120 was superseded by Rule 2060. What does this mean to you? Although the rule book consolidation is still underway, the implementation of Dodd-Frank is not complete and your compliance program requires continuous attention and updating. All while you maintain your daily business operations.
Action items: a) review your compliance manual regarding the rule changes which have been adopted; b) adapt the applicable rules into your manual(s); c) follow the rule changes being proposed; and d) edit your procedures where applicable and implement within your compliance program.
Or, call upon RegMaven to work with you and your team to monitor, edit, adopt and successfully implement. We can be found at www.regmaven.com , info@regmaven.com or 603.965.7791. We look forward to speaking with you.
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