SEC and FINRA Exam Priorities to Include Firms’ AML Compliance Programs, Including Policies and Procedures

SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued its examination priorities for 2020. According to the document, OCIE will assess the adequacy of firms’ AML compliance programs, including relevant policies and procedures. AML Compliance was also cited by FINRA as an area of focus in its recent 2020 Risk Monitoring and Examination Priorities Letter.

The Bank Secrecy Act requires financial institutions, including broker-dealers and investment companies, to establish anti-money laundering (AML) programs. These programs must, among other things, include policies and procedures reasonably designed to identify and verify the identity of customers and beneficial owners of legal entity customers…Given the importance of these requirements, OCIE will continue to prioritize examining broker-dealers and investment companies for compliance with their AML obligations...”
– 2020 SEC Examination Priorities

Do you have the right tools in place to manage AML compliance?

Training
A robust training program is a core element of compliance with anti‐money laundering regulations. RegEd’s Anti-Money Laundering Training solutions deliver a streamlined user experience that enables insurance and securities professionals to satisfy AML training requirements with minimal disruption, while enterprise reporting capabilities enable administrators to monitor requirements and completion status.

Policies and Procedures
RegEd’s Policies and Procedures Management provides an enterprise workflow and task management solution that enables comprehensive, end-to-end administration and oversight of all elements of the firm’s policies and procedures.

Read more about RegEd’s Policies and Procedures Management solution.

Read more about RegEd’s AML training solution.

RegEd Leaders Elected to Positions at the SILA Foundation and SILA Education and Training Subgroup (SETS)

RegEd, the leading provider of compliance technology solutions to the financial services industry, today announced that members of its Regulatory Affairs Group have been elected to serve in positions at the SILA Foundation and SILA Education and Training Subgroup (SETS).

Susan Boles, RegEd Senior Regulatory Compliance Analyst, has been elected to the SILA Foundation Board of Trustees as the new Scholarships & Grants Trustee Member. As the new Scholarships & Grants Trustee Member, Susan will oversee all of the scholarship programs and grants that SILA issues.

Brandi Brown, RegEd Senior Vice President of Regulatory Affairs, is now Co-Chair of the SILA Education and Training Subgroup (SETS). The SILA Education and Training Subgroup (SETS) provides a forum for SILA Members to address issues related to Education and Training Requirements for Producers, Adjusters, and Registered Representatives.

Newly appointed Scholarships & Grants Trustee Member, Susan Boles, commented “I’m honored to have been elected as the new Scholarships & Grants Trustee Member on the SILA Foundation Board of Trustees. I have been an avid supporter of the SILA mission for years with RegEd and to be able to serve on the foundation board is one of the best ways I can think of to assist and give back to my profession.”

The purpose of the SILA Foundation is to provide an educational forum for the public. The SILA Foundation Board of Trustees determine what programs, whether in person and online, should be offered. The educational content offered covers Financial Services, specifically Securities and/or Insurance, and its purpose is to develop and/or improve individuals’ capabilities regarding Financial Services. Activities may include educational materials, courses, public discussion groups, forums, panels, lectures, personal career development, mentoring, job training, job fairs, or other programs.

To learn more about the SILA Foundation, please visit http://www.silafoundation.org/.

About RegEd

RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.

Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.

Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.

Market Conduct Exams: Best Practices to Ensure a Smooth Process and Stay Under the Radar for Future Examinations

By Merlinda Johnson FLMI, ACS and Rebecca Vasquez, Esq.

For an insurance company, the key objective of a market conduct examination (MCE) is to avoid it. As regulators pay more attention to problem areas, behaving well in the marketplace in the first place mitigates the chances of being examined. The No. 1 defense against an unscheduled market conduct examination is a documented and well managed compliance program, and companies that follow a few best practices find they can stay under the regulatory radar, and when they are selected for examination, they can be fully prepared to make it go smoothly.

1. Know the handbook.

The NAIC’s Market Regulation Handbook Examination Standards Summary (available free of charge as a downloadable PDF) is a high-level compilation of the market conduct standards found in the more complete Market Regulation Handbook, available from the NAIC, details each function within an organization that a market conduct examiner would review during the exam process.

  • Make sure your policies and procedures align with each standard in the summary. If they do, you probably have a robust compliance framework already, and you’d be prepared for a regulatory examination.
  • Monitor and measure these standards. For example, one standard is complaint handling. During an MCE, an examiner will review a company’s complaint records to ensure it follows these standards. This includes complaints being recorded properly and the company taking adequate steps to resolve them appropriately.

2. Understand common exam triggers.

Regulators pay close attention to these areas. Manage them successfully to lessen the frequency of being examined.

  • Complaints: The most frequent trigger for a market conduct exam.
  • Claim denials and slow payments
  • Policy cancellations and non-renewals
  • Drastic changes in premiums
  • Regulatory action or activity in other states: State departments of insurance (DOI) compile data in their jurisdictions and share it with other DOIs. A red flag in one state can trigger investigations in others.
  • Market Conduct Annual Statement (MCAS) outliers: MCAS results can be a strong indicator of a possible market conduct examination. Regulators look for outliers in the results, like the number of complaints, claim denials, and other metrics.
  • New laws and regulations: New laws and regulations are being adopted around evolving functions, such as cybersecurity and health care, and regulators focus on how insurers keep on top of the changes.
  • Market share and premium growth: Larger organizations may tend to be examined more often than smaller market participants.

3. When it comes time for an exam, be prepared and establish a defined process.

If you are chosen for an exam, show that you have your house in order and conduct yourself positively for the best possible result.

  • Appoint an exam coordinator who has thorough knowledge of the company, its organization, and its processes. A well-appointed coordinator can expedite the process and encourage a positive result.
  • Prepare for the examiner’s arrival in advance, having read the coordinator handbook, if relevant. Provide a comfortable, welcoming workplace and fully functioning technology to avoid unnecessary delays. Being friendly, accommodating, respectful, and collaborative can only help—especially when negotiating points in the final report.
  • Respond to exam criticisms quickly. Acknowledge any deficiencies, own them, and work with the examiner to develop a remediation plan in a timely manner to keep the project on track.
  • Build a process to manage workflow and data. Ideally, an organization would use technology to facilitate the exchange of information between examiners and different parts of the company.

4. Utilize technology that is designed for the job.

Many organizations still use ’90s-vintage technology—email, spreadsheets or a secure file share—for market conduct exams, making the process ad hoc, reactive, cumbersome, and unreliable. A system that orchestrates all the moving parts can ensure a vastly better outcome.

  • A purpose-built solution that manages tagged and searchable market conduct content specifically, rather than fishing for information in email and shared files manually. This allows for more timely and accurate responses to examiners’ criticisms during the market conduct exam process.
  • Created by people experienced in the market conduct exam process and uses structured project templates to replace manual task tracking.
  • Accommodation of staff involved by identifying and notifying each one in advance, allowing for preparation of any obligations and tasks well ahead of deadlines, and enabling collaboration among them during the process.

5. More Best Practices

  • Create, test, and verify the implementation of policies and procedures for each exam-triggering area. For example, analyze complaint data to identify trends and implement appropriate corrective action. Implement a solid complaint tracking system that allows for effective management of complaints, and any uptick in complaints should be investigated immediately.
  • Go to the regulators before they go after you by self-reporting compliance issues before they rise to a regulator’s attention. Most DOIs look favorably on companies that do this.
  • Review recent examination results of other companies, which are published on some state department of insurance websites. These can provide insight into different states’ market conduct priorities. For example, one state may be more focused on privacy issues while another looks closely at property & casualty claims.

RegEd is ready to assist insurance companies manage the process of a market conduct exam, including task management, document management, communication with the examiners, documentation, audit trails, reporting, and more, supported by efficient and enabling technology and people with deep experience in the process.

Learn more about our Market Conduct Exam Management solution.

About the Authors

Merlinda Johnson

Merlinda Johnson is the Director of Insurance Regulatory Compliance at RegEd, Inc.

Rebecca Vasquez

Rebecca Vasquez is a Senior Regulatory Analyst/Publisher at RegEd, Inc.

FINRA Priorities Letter Highlights Customer Communications as the Subject of Heightened Focus for 2020

FINRA’s 2020 Risk Monitoring and Examination Priorities Letter serves to document areas of emphasis for the coming year, which firms may consider for opportunities to improve their compliance and supervisory programs. Among the highlights in the 2020 letter is an emphasis on firms’ compliance with obligations relating to FINRA Rule 2210 (Communications with the Public), including their marketing, advertising and sales materials.

FINRA will review how firms review, approve, supervise and distribute retail communications regarding private placement securities via online distribution platforms, as well as traditional channels.
– FINRA 2020 Risk Monitoring and Examination Priorities Letter

Learn how leading firms partner with RegEd to streamline advertising compliance review and drive faster time to market.

Leading firms that together employ hundreds of thousands of registered representatives have selected RegEd’s Advertising Review, which delivers a single, integrated solution that streamlines the end-to-end processes for advertising and customer communication submission, review, collaboration and approval, speeding time to market for review items.

Read more about RegEd’s Advertising Review solution.

Case Study: Learn how CUNA Mutual increased efficiency in their advertising review process

SEC’s 2020 Examination Priorities Demonstrate a Continued Focus on Conflicts of Interest, Including Outside Business Activities

SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued its examination priorities for 2020. According to the report, OCIE will continue its focus on the protection of retail investors, including seniors and those saving for retirement. Examinations in these areas will include reviews of disclosures relating to fees, expenses, and conflicts of interest.

“Registered firms must effectively implement controls and systems to ensure disclosures are made as required and that a firm’s actions match those disclosures… Examinations will relatedly focus on registered firms’ disclosures and supervision of outside business activities of its employees and associated persons, and any conflicts that may arise from those activities.
– 2020 Examination Priorities, Office of Compliance Inspections and Examinations, U.S. Securities and Exchange Commission

Do you have the right tools in place to manage conflicts of interest?

RegEd’s fully integrated Conflicts of Interest Management solution suite enables firms to seamlessly monitor, identify and remediate conflicts of interest and code of conduct issues. The solution captures a full audit trail of requests, approvals, exceptions and remediation, and provides ready documentation for internal and external regulatory reporting.

The solution suite, including Outside Business Activities, leverages RegEd’s powerful platform capabilities to enable comprehensive monitoring, task management, alerts and sophisticated hierarchy management.

Read more about RegEd’s Conflicts of Interest solution suite.

Read more about RegEd’s Outside Business Activities solution.

RegEd Appoints Derrick D. Cobey as Chief Technology Officer

Technology strategist and product development veteran to drive the continued advancement of RegEd’s enterprise compliance and credentialing solutions.

RegEd, the market-leading provider of enterprise regulatory compliance solutions to banks, broker-dealers, insurance companies and brokers, is pleased to announce its appointment of Derrick D. Cobey to the role of Chief Technology Officer (CTO). In this role, Cobey will direct RegEd’s technology strategy and drive continuous innovation across RegEd’s broad compliance and credentialing solutions portfolio.

“As client expectations for technology-enabled efficiency continue to evolve, a chief technology officer that is an innovation agent with highly disciplined execution is critical to our continued success” said John M. Schobel, RegEd CEO and Founder. “Derrick brings extensive knowledge of product engineering, technology strategy, SaaS solutions development and systems architecture and design, in combination with a successful track record of delivering enterprise software solutions that are competitively distinguished, to RegEd. His proven ability to execute technology and product transformation strategies and drive highly disciplined SLDC practices will help ensure RegEd’s continued success.”

Cobey is a highly accomplished technology and business leader with more than 20 years of software development and SaaS solution experience.  He joins RegEd from hCentive, where he was Chief Product Officer and General Manager, Government Solutions. At hCentive Derrick was responsible for the company’s overall strategic direction and day-to-day operations on a global level.  In his prior career, Derrick was the Chief Technology Officer for Mediware Human Services (now WellSky), Senior Vice President of Product and Solutions Engineering at PeopleClick (now PeopleFluent) and the Vice President of Product Engineering at JPMorgan Chase.  During his time at these companies, he led globally distributed teams in engineering SaaS solutions and fast-growth enterprise software.

“I’m thrilled that Derrick has joined RegEd at this exciting point in our growth,” continued Schobel. “Derrick’s technology expertise and proven track record in roles at high-growth companies make him an excellent fit to continue to drive RegEd’s culture of innovation, and I’m confident that he’ll make material contributions to RegEd’s future.”

About RegEd

RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.

Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.

Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.

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FSI OneVoice 2020

RegEd CEO and Founder to be a Featured Presenter at FSI OneVoice 2020

John M. Schobel will present on the topic of driving efficiency and effectiveness in branch exams and field audits.

RegEd, the leading provider of compliance technology solutions to broker-dealers and other financial services firms, is pleased to announce its participation in the Financial Services Institute (FSI) OneVoice conference in San Diego, CA, January 27-29, 2020.

RegEd Founder and CEO, John M. Schobel, will present on Improving Branch Exams on Tuesday, January 28th at 1:30 PM. The session will cover how branch exams and field audits can be made more beneficial and impactful for both the firm and the registered representative. The session will review the topics to cover in the exam as well as evaluate how to best approach compliance issues and create an open dialogue.

John M. Schobel, Chief Executive Officer at RegEd, commented, “The need for a holistic view of compliance and risk is the key driver causing industry firms to consolidate compliance technology in favor of an enterprise approach. RegEd’s enterprise compliance platform and wide breath of compliance solutions, including Branch Audit Management, enable our clients to establish a central compliance portal that provides their advisor and employee population with a full view of compliance requirements and status while providing the firm with the critical views needed to reduce overall risk for the firm.”

The FSI OneVoice conference is an educational forum for broker-dealer home office executives. This year’s event will offer more than 30 sessions on topics surrounding compliance, supervision, operations and technology. Presenters and panelists include regulators, senior executives from leading financial services firms and industry subject matter experts.

RegEd will be an exhibitor and sponsor at the conference, and will showcase enterprise solutions that enable firms to ensure a culture of compliance in today’s rapidly evolving regulatory environment:

Branch Audit Management: Enables firms to fully plan, schedule, conduct, resolve and report on branch audits. Streamlines the audit process and improves efficiency of the firm’s audit program.

Gifts, Gratuities and Contributions Management: Expanded capabilities enable global enterprise gifts and entertainment tracking and management, including: automated contact management, threshold tracking, automated alerts, and more.

Enterprise Advertising Review: Enable a workflow-driven process to streamline advertising and customer communication submission, review, collaboration and approval, speeding time to market for review items.

Registration and OBA: Streamline registration compliance across the enterprise, including end-to-end OBA tracking and reporting. Integrations automate filing and reconciliation of amendments and background investigations.

RegEd representatives will be on-site to meet with conference attendees to understand their compliance challenges and discuss solutions that enable broker-dealers and other financial services firms to meet compliance requirements and proactively manage their compliance program.

The RegEd conference exhibit will be located at booth #509 in the conference’s main exhibitor hall at the Sheraton San Diego Hotel & Marina. For more information on RegEd or its attendance at the FSI OneVoice conference, please call 800-334-8322 or email sales@reged.com.

About RegEd

RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.

Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.

Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.

RegEd Recognized as a Leading Compliance Technology Provider by CIO Review and Banking CIO Outlook

The annual awards acknowledge companies that are at the forefront of providing compliance and risk solutions while significantly impacting their industries.

RegEd, the leading provider of compliance technology to insurance companies, broker-dealers and banks, today announced that CIO Review and Banking CIO Outlook, prominent publications for information technology executives, have selected RegEd as one of the 20 Most Promising Compliance Technology Providers and one of the Top 10 Risk and Compliance Solution Providers for 2019.

CIO Review and Banking CIO Outlook produce an annual list of providers that are at the forefront of providing compliance and risk solutions to the financial services industry. The goal of the awards is to spotlight companies with a proven track record in effectively delivering compliance solutions, while enabling decision makers in financial institutions to stay well-informed on industry trends through research and evaluation of the vendor marketplace.

RegEd CEO & Founder John M. Schobel said, “RegEd provides solutions that propel operational efficiency, enabling firms to cost-effectively comply across core compliance functions.” He continued, “RegEd is honored to receive these awards and to be recognized as a leader in our market. And we’re grateful to CIO Review and Banking CIO Outlook for enabling industry participants to make informed, evidence-based decisions when choosing the technology that is so integral to their business.”

To learn more about RegEd and its industry-leading compliance platform, visit RegEd.com.

About RegEd

RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.

Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.

Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.

RegEd Appoints Glen Jasionowski as Chief Revenue Officer

RegEd, the market-leading provider of enterprise regulatory compliance solutions to banks, broker-dealers, insurance companies and brokers, is pleased to announce its appointment of Glen Jasionowski to the role of chief revenue officer (CRO). In this role, Jasionowski will direct RegEd’s enterprise sales strategy and execution to meet and exceed growth objectives.

“Glen brings extensive knowledge of enterprise software and the financial services industry, in combination with a successful track record of consultative client engagement, to RegEd,” said John M. Schobel, RegEd CEO and Founder. “His proven ability to execute growth strategies in the compliance management software industry will help ensure RegEd’s continued success.”

Jasionowski is a highly accomplished sales and business leader with significant experience in leading sales organizations through transformation focused on sales enablement and customer success that delivers consistent revenue growth and client satisfaction. He joins RegEd from FIS, where he was Managing Director, Head of Global Major Accounts, owning the global sales and relationship strategy for enterprise financial services accounts including the largest global banks. At FIS Glen and his team drove consistent achievement of revenue and customer success goals. Prior to FIS, Glen spent a significant part of his career selling enterprise solutions at Experian with a focus on financial services.

“I’m thrilled that Glen has joined RegEd at this exciting point in our growth,” continued Schobel. “He’s a strong addition to our executive team and I’m confident that he’ll make material contributions to RegEd’s future.”

About RegEd

RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.

Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.

Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.

RegEd Hosts Policy Management by Design Workshop in Chicago

Workshop featured internationally recognized pundit on governance, risk management, and compliance.

RegEd, the leading provider of compliance and risk management technology to broker-dealers and other financial services firms, hosted a Policy Management by Design workshop in Chicago, IL, on October 30, 2019.

Workshop attendees explored how defining the right process, information and technology architecture for policy management can create a structured approach to how the organization operates. Attendees were equipped to define a process lifecycle for managing policies, establish policy ownership and accountability, track policy attestation, and map policies to objectives, risks, controls, issues, and other GRC areas.

The full day workshop was led by GRC expert Michael Rasmussen, an internationally recognized pundit on governance, risk management, and compliance. Michael helps organizations improve GRC processes, design and implement GRC architectures, and select solutions that are effective, efficient, and agile. He is a sought-after keynote speaker, author, and advisor and is noted as the “Father of GRC” — being the first to define and model the GRC market in February 2002 while at Forrester Research, Inc.

GRC Expert Michael Rasmussen stated, “Policy management by design requires a structured approach in context of how the organization operates. This is done through defining the right process, information and technology architecture for policy management.” Rasmussen continued, “This workshop was the perfect opportunity for attendees to learn how using technology can enhance policy management processes and how critical it is in supporting your businesses GRC initiatives.”

For more information on future RegEd workshops, please contact events@reged.com.

About RegEd

RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.

Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.

Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.

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