Lessons on Effective Supervision

supervise

Radical Compliance rarely looks at corporate misconduct as obscure as a broker-dealer improperly trading in the market for U.S. Treasurys, but trust me on this: a FINRA enforcement action last week on exactly that issue does indeed offer the larger compliance community a few lessons worth learning. Let’s take a look. The broker-dealer in question…

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FINRA Talks Cyber Risks

cybersecurity

FINRA, the regulator for broker-dealer firms that every other compliance professional should follow anyway, has given us yet another piece of nifty guidance: its annual report on regulatory examinations, brimming with advice about risks related to cybersecurity, anti-money laundering, and other issues.  Like most other financial regulators, FINRA examines the compliance programs of businesses under…

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FINRA’s Olive Branch on CCO Liability

cco liability

FINRA, the regulator for broker-dealer firms, is trying to ease tensions over chief compliance officer liability with a new alert stressing that FINRA typically will not bring enforcement actions against CCOs personally because compliance officers don’t inherently have a supervisory role at their firms.  FINRA published the alert late last week, after several pleas from…

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New FINRA Guidance on Pandemic Risks

vaccination

Another day, another gumdrop of guidance from financial regulators that’s worth reading for the whole compliance community. This time it’s FINRA, which published a bulletin Monday reminding broker-dealer firms about how to manage pandemic risk. FINRA has Rule 4370 for broker-dealers, which requires them to draft and maintain a business continuity plan. That rule doesn’t…

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All the Cool Kids Worry About Fintech Now

Finally, proof that U.S. regulators can grasp new trends or stay current on modern business issues: with startling speed and coordination, every regulator who’s any regulator has started worrying about fintech. “Fintech” is startup-speak for financial technology, a branch of the financial world that was huge already, and for some reason has suddenly captivated regulators attention all over again.…

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Implementing Compliance for Robo-Advisers: 4 Points

Well, so much for automating your investment advisers out of a job and not worrying about that part of the business any more. Last week FINRA published new guidance about robo-advisers, or in agency parlance, “digital investment advice”—the automated investment tools financial firms offer to customers so they can self-pilot stock portfolios, IRA accounts, and…

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Meeting FINRA’s Focus on Culture for 2016 Reviews

Good news for compliance officers joyously eager to participate in your firm’s FINRA reviews this year: FINRA has just published its examination priorities for 2016, and you will be involved up to your eyeballs. FINRA grouped its exam priorities into the categories of culture and ethics; risk management and controls; and liquidity. None of those is…

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