Regulatory Insights Regarding Compliance Assessments of Regulation Best Interest and Form CRS

These are certainly interesting days.  So much is taking the attention of compliance professionals.  By now everyone has implemented their business continuity plans (BCP) and likely made modifications to them here and there as the true test of these plans has been realized.  BCP has now become yet another compliance ball to juggle for the foreseeable future.  BCP recordkeeping will be important so be sure to track as you go.  Regulators are certain to ask about this in upcoming exams. Now that everyone is settled into their temporary work environments and any BCP gaps have been shored up, the looming […]

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Key Takeaways: FINRA’s 2019 Report on Examination Findings and Observations

On October 16, 2019, FINRA published its 2019 Report on FINRA Examination Findings and Observations.  This report is a useful resource for firms to leverage to improve their compliance and risk management programs.  One of the findings in the report pertains to failure to effectively monitor for and react to regulatory changes.  Firms are required to review regulatory changes against their supervisory systems, including their written supervisory procedures and training programs.  FINRA found that some firms did not adequately respond to recent regulatory changes such as FinCen’s new Customer Due Diligence (CDD) obligations and requirements around Financial Exploitation of Specified […]

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