CSS Blog – Compliance Solutions Strategies https://www.compliancesolutionsstrategies.com The Best of Breed in Regulatory Data Solutions. Thu, 06 Jun 2019 15:48:24 +0000 en-US hourly 1 Creativity vs. Compliance: When Marketing Just Doesn’t Seem to Get It https://www.compliancesolutionsstrategies.com/creativity-vs-compliance-when-marketing-just-doesnt-seem-to-get-it/ Thu, 06 Jun 2019 15:48:24 +0000 https://www.compliancesolutionsstrategies.com/?p=6012 Continued]]> We’ve all been there before…you get a request to review marketing materials, and there’s urgency to it. Great! You’ve successfully trained the firm to make sure things are run by you first. The problem is it’s 4:15pm and they need to get it out by the end of the day. You open up the document, see some unsupported performance numbers, maybe a testimonial or two, and some language that’s so flowery...

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SEC Adopts Regulation Best Interest, Form CRS; Also Issues Interpretive Releases on IA Fiduciary Duty and Solely Incidental Exception https://www.compliancesolutionsstrategies.com/sec-adopts-regulation-best-interest-form-crs-also-issues-interpretive-releases-on-ia-fiduciary-duty-and-solely-incidental-exception/ Wed, 05 Jun 2019 18:55:18 +0000 https://www.compliancesolutionsstrategies.com/?p=5990 Continued]]> By a 3-1 vote, on June 5, 2019, the SEC acted to provide a new regulatory framework to help retail, or main street, investors understand the distinctions between broker-dealers and investment advisers, particularly the standards of conduct owed by each. Opening remarks by SEC Chair Jay Clayton noted that as markets have developed over the last century, this issue has grown in importance with more...

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Reorgnization of FINRA’s Examination Program Taking Shape https://www.compliancesolutionsstrategies.com/reorgnization-of-finras-examination-program-taking-shape/ Thu, 30 May 2019 20:54:53 +0000 https://www.compliancesolutionsstrategies.com/?p=5954 Continued]]> At FINRA’s recent annual conference in Washington D.C., President and CEO Robert W. Cook and Executive Vice President of Member Supervision Bari Havlik discussed, among other things, FINRA’s ongoing efforts to consolidate its Examination and Risk Monitoring Programs from three separate programs into a single one. The goal of the reorganization is to drive more effective risk monitoring by better...

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SEC Begins Cyber Sweep of Investment Advisers with Focus on Cloud Storage https://www.compliancesolutionsstrategies.com/sec-begins-cyber-sweep-of-investment-advisers-with-focus-on-cloud-storage/ Fri, 24 May 2019 15:05:38 +0000 https://www.compliancesolutionsstrategies.com/?p=5867 Continued]]> A sweep of investment advisers is underway by the U.S. Securities and Exchange Commission, which has sent out many letters to firms over the last week requesting information about their use of cloud providers. The move could be part of the SEC’s Phase 3 Cybersecurity Exam Initiative, and is likely related to the April Regulation S-P Risk Alert about how firms are protecting personally identifiable...

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What Happens When Your CRM is Breached? https://www.compliancesolutionsstrategies.com/what-happens-when-your-crm-is-breached/ Fri, 24 May 2019 06:03:23 +0000 https://www.compliancesolutionsstrategies.com/?p=5872 Continued]]> Even your client relationship management (CRM) software may not be safe from hackers. That’s the lesson some advisers are learning after an announcement by CRM vendor Redtail that it discovered in March 2019 that its cloud-based software had left some sensitive client data publicly accessible. The data left vulnerable included first names, last names, addresses, dates of birth...

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Introduction to SFTR ‘Cheat Sheet’ https://www.compliancesolutionsstrategies.com/introduction-to-sftr-cheat-sheet/ Mon, 20 May 2019 13:50:13 +0000 https://www.compliancesolutionsstrategies.com/?p=5747 Continued]]> SFTR is designed to enhance transparency of Securities Finance Transactions (SFTs) for all financial and non-financial EU entities and, branches of non-EU entities. The reporting obligation begins 11 April 2020 for investment firms, followed by a nine-month phased approach for other firms. Need a quick introduction to the key details of the regulation? Download our “Introduction to SFTR&#

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Even When SEC Rulemaking Slows, Your Compliance Manual Shouldn’t Stagnate https://www.compliancesolutionsstrategies.com/even-when-sec-rulemaking-slows-your-compliance-manual-shouldnt-stagnate/ Fri, 10 May 2019 12:30:19 +0000 https://www.compliancesolutionsstrategies.com/?p=5717 Continued]]> Maintaining tailored policies and procedures is a critical component of an adviser’s internal controls. Time and time again, we’ve heard regulators admonish the industry that off-the-shelf compliance manuals just don’t cut it. In today’s ever-shifting regulatory environment, does your compliance manual need a reboot? Although there has not been any significant rule making over the past year...

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Life Cycle Guidance for Service Provider Due Diligence https://www.compliancesolutionsstrategies.com/life-cycle-guidance-for-service-provider-due-diligence/ Thu, 09 May 2019 16:28:15 +0000 https://www.compliancesolutionsstrategies.com/?p=5713 Continued]]> Engaging third-party service providers to perform key functions can offer an investment adviser access to state-of-the-art technology and solutions necessary to compete in today’s environment. Before entering into service provider relationships, advisers need to understand that while the function may be outsourced, the responsibility for the function still rests with the adviser.

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Takeaways and Tips Related to SEC Risk Alert on Regulation S-P https://www.compliancesolutionsstrategies.com/takeaways-and-tips-related-to-sec-risk-alert-on-regulation-s-p/ Wed, 08 May 2019 15:27:14 +0000 https://www.compliancesolutionsstrategies.com/?p=5707 Continued]]> On April 16, 2019, the SEC released a Risk Alert providing a list of compliance issues related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment advisers and broker-dealers. As with other risk alerts, these were deficiencies noted by OCIE in regulatory examinations. Though the deficiencies were fairly common sense, the release of the risk alert...

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Refreshing the Annual Review Process to Address Business and Regulatory Risks https://www.compliancesolutionsstrategies.com/refreshing-the-annual-review-process-to-address-business-and-regulatory-risks/ Tue, 07 May 2019 16:26:09 +0000 https://www.compliancesolutionsstrategies.com/?p=5699 Continued]]> Rule 206(4)-7 requires each registered adviser to review its policies and procedures no less frequently than annually, to determine their adequacy and the effectiveness of their implementation. But what’s the best way to approach this review? How are other firms meeting this requirement? At the recent Ascendant Compliance Solutions Strategies 2019 Spring Conference in Miami Beach...

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