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 the 26 Red Flags included in the supplement? Have you designed your implementation plan and training?
This rule can be implemented in a couple of ways. Many of the requirements will overlap with your AML procedures and also certain AML filings, such as a SAR Report. Your adherence to the new regulation will also impact other compliance functions regarding the maintenance and testing of the regulation.
In order to implement this rule effectively, you should know not only your systems, but also your vendor’s systems, compliance monitoring procedures and your client transaction habits. Identity theft is a growing concern today and broker-dealers, registered investment advisors and fund companies are exposed just as much as any bank or other creditor.
RegMaven is experienced in designing and building policies and procedures for new regulations. We review your internal programs currently in place, assess your resources and design a plan that is effective and easily adaptable to rule amendments. Contact us for a discussion regarding this new regulation before the regulators do: www.regmaven.com or info@regmaven.com
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