During 2019, the Securities and Exchange Commission (“SEC”) issued an abundance of enforcement actions against financial firms, issuers, and auditors that involved disclosure deficiencies.[1] For financial firms, a majority of these circled around inaccurate, incomplete, or lack of disclosures involving … Read More
What is “Outsourcing”? Outsourcing can be defined as the act of contracting certain work or services out to a third party, typically as a replacement for conducting that service internally. In today’s market, many organizations choose to outsource specific, everyday … Read More
Managing Conflicts Managing a broker dealer’s gifts and business entertainment conflicts can be an ongoing challenge for even the best compliance team. This task can become even more challenging as the holidays approach. You want to thank your clients for … Read More
Proper Portfolio Management and Trading are Regulatory Priorities: In its 2019 Examinations Priorities Letter, the Securities and Exchange Commission (“SEC”), Office of Compliance Inspections and Examinations, listed Portfolio Management and Trading as SEC Examinations priorities.[1] Many Firms are unaware of … Read More
As 2020 looms on the horizon, Chief Compliance Officers (“CCOs”) should begin laying out their compliance roadmaps for the New Year. An area of review that should undoubtedly be a part of CCOs’ 2020 planning is cybersecurity. Cybersecurity remained at … Read More
With another year winding down, compliance personnel needs to begin evaluating the status of compliance projects and schedule any remaining tasks to ensure completion. Consideration of any regulatory changes, guidance, and risk alerts issued during the year, emerging best practices … Read More
Under Rule 206 (4) -7 all Registered Investment Advisers (“RIA’s) are required to have compliance Policies and Procedures, adequately designed to help them meet their regulatory requirements. A Firm’s obligations regarding their Policies and Procedures manuals do not end at … Read More
Firms registered with the Securities and Exchange Commission (“SEC”) are mandated by Rule 206(4)-7 (“Compliance Rule”) to perform an annual review of their policies and procedures, and a key component of a firm’s annual review should include cybersecurity testing. Cybersecurity … Read More
Planning for the Task As the summer solstice approaches, now is a good time for broker-dealer compliance personnel to begin planning for the annual compliance meetings (“ACMs”), required under FINRA Rule 3110(a)(7). Specifically, each registered representative and registered principal of … Read More
Every registered investment adviser and employee of the adviser have a fiduciary duty to put their clients’ interests ahead of their own. The Securities and Exchange Commission (“SEC”) has often emphasized that the key to a successful compliance program is … Read More