broker-dealers | Oyster Consulting

SEC Posts 2018 Exam Priorities

February 9, 2018

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released its 2018 National Exam Program examination priorities yesterday. 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 “Disclosures of the Costs of […]

FINRA Sweep: Order Routing and Conflicts of Interest

November 20, 2017

FINRA (Financial Industry Regulatory Authority) sent targeted examination letters to a select group of broker-dealers requesting information as part of a review of how firms handle situations in which conflict of interest arises related to payments or other inducements for order routing. These letters came from the Trading & Financial Compliance Examinations (TFCE) section in […]

FINRA 2018 Renewal Calendar – It’s Time to Fund Your CRD Account

November 13, 2017

It’s that time again—Thanksgiving is around the corner, football season is in full swing and FINRA has published its 2018 Renewal Calendar. Firms are required to renew their registrations annually through the Renewal Process, which begins in the fourth quarter of each year. The 2018 Renewal Program begins today November 13, 2017, when FINRA makes […]

Are Your Business Continuity / Disaster Recovery Plans Ready for ____________________?

September 7, 2017

How you complete and answer that question could be the difference between your firm’s survival or not. Business Continuity and Disaster Recovery plans are designed to ensure that your firm is able to provide critical services during a time of crisis and also survive and recover from disasters. An effective plan must be designed to […]

Webinar Slides Available: Vulnerable Adult Clients – Are Your Protecting Your Clients and Your Firm?

June 5, 2017

Confused about the new FINRA rule requirements around senior and vulnerable adult exploitation? Not sure what you should be doing to protect your firm and your clients? On May 25, 2017 Oyster Consulting hosted a webinar addressing the new and amended FINRA rules, what firms should be doing now, and the need for escalation and […]

Are You Ready for June 9th and the DOL Fiduciary Rule?

March 27, 2017

The Department of Labor (DOL) has proposed to delay the applicability date of its fiduciary rule by 60 days. The new compliance date and the beginning of the transition period under the proposed delay is June 9th. Even with a delay, numerous questions remain and nobody knows for sure what June 9th will bring. Join […]

Alert – The SEC Division of Investment Management Issues Robo Advisor Guidance Update

March 2, 2017

Regulators are taking a close look at electronic investment advice. After specifically mentioning the topic in the SEC’s 2017 Exam Priorities Letter, last week the SEC Division of Investment Management issued a Guidance Update covering: Disclosures to be made about the robo-advisor and the services offered Advisor’s obligation to obtain client information necessary to providing […]

Supervisory Controls Testing – Is Rule 3120 On Your To-Do List?

January 24, 2017

Planning Your Compliance Calendar The beginning of the year is often a time for getting organized; reviewing and updating your firm’s compliance calendar to include FINRA’s required annual supervisory controls testing and reporting should be on your to-do list. FINRA Rule 3120 requires broker-dealers to have in place a system of policies and procedures that […]

Cross-Selling – Are You Prepared if Regulators Target More Firms?

December 12, 2016

In 2016 FINRA sent a “sweep letter” to selected firms requesting the information about cross-selling incentives for broker-dealer employees. These sweep letters and the information they request are often a roadmap showing how firms should be evaluating their Compliance Programs – in this case, around cross-selling incentives. What Should my firm be doing? Firms should […]

AML and OFAC – Will Your AML Program Stand Up to Scrutiny?

December 1, 2016

It was announced in early November 2016 that $215 million will be paid to New York state by Agricultural Bank of China for engaging in “intentional wrongdoing,” including masking possibly suspicious transactions, at its New York branch. The New York State Department of Finance stated that some transactions involved parties subject to U.S. sanctions. Red […]

Protect Senior Investor and Vulnerable Adult Clients

October 27, 2016

The challenge of diminished capacity presents a major risk to your clients and their families if they are not prepared. It also presents a risk to the firm if you are not aware of how to address these issues. As the number of vulnerable investor exploitation claims grows, FINRA and the SEC have increased their […]

Branch Exams and Program Design

September 22, 2016

Branch exams are a critical part of every broker-dealer’s system of compliance and controls, and must address risk while ensuring your firm is complying with relevant rules and regulations. Branch exams are more than just walking into a location and working from a standard checklist. Branch location types, business lines, products, firm changes and varying […]

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