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last modified: 24 Feb 2017
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February 24, 2017 – Robo advisors are officially on the SEC’s radar

The SEC has issue guidance for firms that offer automated advice platforms to their clients in an effort to meet their legal obligations. In addition to discussing potential considerations under the Investment Advisers Act of 1940 and a discussion about the actual business model of a robo-adviser, there are several areas that firms should keep in mind when creating their compliance programs. Click here to read the Guidance.

 

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Both FINRA and the SEC published their exam priorities for this year and links to both are below. While some of the topics may not be applicable to your business model, it’s always smart to see what both are thinking.

 

The Department of Labor published several sets of Frequently Asked Questions (FAQ), some as recent as January 23rd so if the new fiduciary rule applies to your business and you need to review them, links are posted under the Compliance Services tab. As fiduciaries, we must pay close attention to the news as there is some movement on both sides of the topic (implementation and delay), but we would be remiss if we relied on a possible snow day.

 

Finally, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to Financial Institutions on Cyber-events and Cyber-Enabled Crime as well as FAQ regarding the reporting of those events on Suspicious Activity Reports (SAR). Links to both documents are located under the AML Audit Services tab.

 

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January 2017 – FINRA publishes Exam Priorities for this year

As in the past, FINRA starts the new year with the publication of its Exam Priorities for the coming year. It is important to read the entire letter with your business model and approved activities in mind. The letter is here for your convenience.

 

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SEC Exam Priorities for 2017

The SEC has also published its Examination Priorities of 2017 which will focus on three general areas: protecting retail investors, risks specific to elderly investors and investment investing and market-wide risks. The move to change business models to accommodate the new requirements of the fiduciary rule may expose investors, and especially elderly investors to new risks. Read the Priorities here.

 


 

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Welcome to Compliance Support Services LLC, a consultancy for small to mid-sized limited purpose broker dealers. Today's ever-changing regulatory environment demands that you have a clear, concise compliance program in place—whether your broker dealer is a long-established firm or new to regulatory requirements.

Compliance Support Services provides solutions and tools to build, organize and maintain the components of an effective compliance program in a knowledgeable, reasonable and dependable manner.

We can help you navigate the complex compliance road-map so you can spend more time focused on your core business activities. Extensive experience in and considerable knowledge of the compliance requirements for broker dealers enables us to deliver the innovative ideas and reliable advice you need. Look to Compliance Support Services to help you interpret new regulations, minimize risk, and capitalize on the investment in your business.


If your challenge is "too many hats and not enough time", or you just need assistance navigating the compliance road-map, you can count on Compliance Support Services for the knowledge and experience to give your compliance program the edge it needs.

Services are offered on an hourly as needed or monthly retainer basis. Complete the Contact form for more information today.

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