Going Paperless Improves Efficiency and Reduces Risk

As firms think about heading back to the office, it is a great time to evaluate Front, Middle and Back Office Operations. What processes transferred seamlessly to a work-from-home environment? What were the pain points in being unable to work in the office? For firms that have not previously transitioned to a paperless environment, reliance… READ MORE

Oyster Welcomes Jeff Gearhart

  Gearhart to focus on growing Trading and Markets services   Jeff Gearhart has joined Oyster’s Strategic Planning and Execution team to focus on growing our Trading and Markets services.   With over 30 years in the financial services industry, Jeff Gearhart’s leadership experience in Capital Markets and broker-dealer businesses bolsters our knowledge base and… READ MORE

Independent Third-Party Reviews: An Important Tool in the Resolution of Regulatory Exams and Investigations

  An effective means to resolve an open examination or enforcement investigation is pursuant to a negotiated settlement with a regulator requiring the services of an independent third party (“ITP”) review. The goal of these reviews is to provide the regulator with a level of comfort to ensure future compliance by the firm. Regulatory settlement… READ MORE

Update: Decommissioning OATS Reporting

FINRA CAT held their monthly implementation update call on Thursday, March 18th, 2021.  In addition to providing normal status updates on CAT reporting, FINRA REG joined the call to provide an important update on the decommissioning of OATS reporting.  As stated in our September 2020 blog on this topic, CAT reporters are extremely eager to… READ MORE

SEC Addresses Climate Change Issues Affecting Financial Markets

Although still in the first quarter of 2021, the U.S. Securities and Exchange Commission (“SEC”) has issued four press releases/public statements on climate change appointments and initiatives: On February 1, 2021 the SEC announced the appointment of Satyam Khanna as a Senior Policy Advisor for Climate and ESG (“Environmental, Social and Corporate Governance”). ESG refers… READ MORE

Reg BI Compliance and “Reasonably Available Alternatives”

FINRA and the SEC have both indicated a greater level of scrutiny and higher level of expectation of compliance with Regulation Best Interest. Of note is their focus on the Care Obligation requirement that representatives assess “reasonably available alternatives” when making a recommendation. Regulators will expect firms to have a process for assessing their product… READ MORE

Highlights from the SEC’s 2021 Exam Priorities

SEC’s Division of Examinations (formerly OCIE) has released their Examination Priorities Report for 2021. While the release is not much of a departure from recent years, some of the older topics have been re-framed to include newer risks and practices. Among “relatively new” topics, the Division will be focusing on Fintech and Innovation, including Digital… READ MORE