Market Access Rule 15c3-5: Still a priority for FINRA

The Market Access Rule (Rule 15c3-5) remains on FINRA’s priority list – they have provided guidance on the rule and initiated enforcement actions against firms struggling to adhere to it. Oyster Consulting often works with clients after regulators have found issues with their Market Access program. It’s in your firm’s best interest to take a proactive look… READ MORE

New Podcast: Understanding Risk-Based Regulatory Exams

For registered financial services firms, regulatory exams in the past have instilled the gamut of emotions from annoyance to anxiety, to outright fear. Fortunately, much of this could be mitigated with a better understanding of the exam process, the necessity for robust risk assessments, and by nurturing the firm’s relationship with it’s regulatory contact. This… READ MORE

Lessons from Regulatory Notice 20-16: Transition to Remote Work and Remote Supervision

FINRA recently released a regulatory notice to help firms understand how their peers are responding to the COVID-19 outbreak.  In this Regulatory Notice (Notice), the FINRA staff shared certain observations based on discussions with member firms about steps taken to transition personnel to a remote work environment.  The observations were not offered as recommended practices… READ MORE

SEC Examinations that Focus on Compliance with Regulation Best Interest

The SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued a Risk Alert to provide broker-dealers with information about the scope and content of its initial examinations for compliance with Regulation Best Interest (Reg BI).  For additional information about the requirements of Reg BI, please see our blog entitled SEC Adopts Reg BI. After… READ MORE

SEC Examinations that Focus on Compliance with Form CRS Requirements

Form CRS and its related rules (“Form CRS”) require SEC-registered broker-dealers and investment advisers to deliver to retail investors a brief customer or client relationship summary (relationship summary) that provides information about the firm.  The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert to provide firms with information about the… READ MORE

What makes a strong FINOP?

FINRA requires all broker-dealers to designate a Principal Financial Officer (PFO), Principal Operations Officer (POO) and a Financial and Operations Principal (FINOP). Each of these positions must have passed the appropriate licensing exam to be registered as a Financial and Operations Principal (Series 27 or 28), depending on the broker-dealer’s business. In small firms, these… READ MORE

New Podcast: 2020 Exam Priorities Letters – Part 1

In case you’re wondering what the regulators will be focusing on this year, they let you know when they publish their annual Exam Priorities Letters. This week’s episode of Oyster Stew is Part 1 in a series discussing the SEC and FINRA 2020 Exam Priorities Letters.  Oyster Consulting CEO Buddy Doyle, Director Evan Rosser and… READ MORE