FINRA’s 2019 Risk Monitoring and Examination Priorities Letter was released last week. While the letter’s second paragraph lists areas of focus which are detailed throughout the report, the third paragraph includes a brief statement about how FINRA will focus on risk related to associated persons with a “problematic regulatory history”. Where there was not a… READ MORE
On January 28th, 2019 the Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 19-04, calling attention to FINRA concerns that firms may have failed to reasonably supervise share class selection in 529 plans. Specifically, customers may have purchased an “inappropriate” share class. FINRA encourages firms to review their controls and determine if any clients were… READ MORE
If you had been listening to all the proclamations on May 25, 2018 when GDPR was to come into effect, you may have been surprised when it felt like any other Friday. GDPR came into effect quietly and no one was fined in all of 2018. Don’t take that to mean that European Data Protection… READ MORE
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released its 2019 Examination Priorities on December 20, 2018. While most of the topics are familiar, there are a few new items of note. OCIE has divided its priorities into four categories: Retail Investors, Including Seniors and Those Saving for Retirement OCIE will… READ MORE
In April 2018, the SEC presented its long awaited rule proposal Regulation Best Interest (“Reg BI”) as a three-part regulatory package aimed at reforming the way that investment professionals serve retail investors. If enacted as proposed, Reg BI would impose upon broker-dealers an obligation to act in a retail customer’s “best interest” when recommending securities… READ MORE
Oyster Consulting Senior Consultant Bob Tuch recently contributed his article, “Protection of Seniors from Financial Exploitation – Congress Enacts the Senior Safe Act” to Practical Compliance & Risk Management for the Securities Industry, a Wolters Kluwer publication. The Senior Safe Act provides immunity from liability to covered financial institutions and certain employees and representatives of… READ MORE
FINRA is expanding its permissive registrations to include all associated persons, including those working solely in a clerical or ministerial capacity. Previously, firms were only allowed to register or maintain the registrations of certain types of job functions (e.g., technology department employees). These changes take effect October 1, 2018. Registered individuals will be subject to… READ MORE
