
By Bill Reilly
Subscribe to our original industry insightsIf 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 reports are deemed to be communications with clients and are governed by FINRA Rule 2210, Communications with the Public.
FINRA Regulatory Notice 10-19 cautioned that inadequately supervised consolidated reports can produce inaccurate, confusing or misleading information, and that firms that cannot supervise the creation and dissemination of these reports must prohibit the use of these reports. Other regulatory considerations for consolidated reports include internal controls, record retention, privacy and safeguarding client information.
Firms that permit the use of consolidated reports must:
Consolidated reports can be an effective means for providing clients with information in one document on multiple accounts held at a broker-dealer and held away. However, broker-dealers should ensure their procedures for developing and delivering these reports meet regulatory requirements.
Oyster Consulting offers our broker-dealer clients a wide array of services. Our team is made up of experienced industry practitioners, not career consultants who have faced the same obstacles you do. From enhancing and testing your Written Supervisory Procedures to training, we can help.
Don’t jeopardize your business by not understanding the latest regulatory news. Click here to learn our current views on this topic, or for a consultation.
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