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
Are Your Internal Controls, Written Procedures and Supervisory Reviews Enough? If you have reviewed the enforcement actions filed by FINRA related to the use of consolidated reports by broker-dealers, you are probably wondering if you are doing enough to protect your firm. Here is what you need to know to help make that determination. Consolidated… READ MORE
Transitioning your platform can be a vital component of making sure your firm is successful for many years to come. Managing your firm’s platform transition is a significant undertaking that will impact most areas of your business. Consistency of communication with your leadership, employees and vendors is just one part of a very complex process…. READ MORE
The economic impact to retail broker-dealers of their clearing strategy is larger than ever. Whether deciding between self clearing vs. fully-disclosed, or choosing the best provider when the answer is obvious, a thoughtful analysis and due diligence must be conducted to achieve your best results. Much is riding on this decision in order to protect your firm… READ MORE
Oyster responds to industry need for operations and compliance experts Nikki Brinkerhoff recently joined Oyster Consulting as an Associate Director, expanding Oyster’s Operations and Compliance practices. The move increases the firm’s ability to help industry members optimize operations and compliance functions, as well as design and implement technology solutions to improve operational excellence, improve… READ MORE
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
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