Regulatory Compliance E-newsletter - January15
Posted On 1/14/2015 11:07:00 AM
Feature of the Month
Improve your 2015 Branch Audit Program
Under the increased scrutiny of today's regulatory environment, your audit program should quickly identify and mitigate risks and protect your firm. Do you feel confident that your program is effective and aids in mitigating risks?
- Can you effectively use your 2014 aggregated audit data in your 2015 Risk Analysis?
- When corrective action is needed are you able to audit the results and easily spot repeat findings?
- Do you have safe storage for audit reports, supporting artifacts and sensitive documents?
- Did you experience a challenge between production and compliance whereby a third party could assist with any possible conflict of interest?
Did you find your 2014 branch audit program challenging and concerning? NRS can increase the efficiency and effectiveness of your program with our Audit Solutions. Whether you're looking for us to manage the process start-to-finish or wish to implement a technology that will standardize your processes and support your audit team, NRS has the solution you need. Choose the option that best fits your firm:
|NRS's staffed audit professional Audit Team conducts the inspections on behalf of the Broker Dealer. The Outsourcing option relieves you of the burden experienced with scheduling and traveling. Allow NRS to conduct the field work and deliver the audit results while you remain in the home office efficiently managing your time and dealing with the high risk areas and rigorous rep oversight.
||A flexible and collaborative approach that allow you to meet expanding audit obligations and control costs. NRS's professional staffed Audit Team will become an extension of your department. NRS is available to visit the outlying areas for the same set cost, absorb unforeseen situations where you may find yourself short staffed or conduct high risk inspections, without any conflict of interest.
||The ComplianceMAX technology can be implemented into any level of Audit Solutions. You will immediately recognize a dramatic boost in productivity and increased job satisfaction. ComplianceMAX consolidates spreadsheets, emails, faxes and other manual processes into one secure and centralized repository for your data, documents and other audit materials.
For more than a decade, NRS has operated the largest and most comprehensive branch inspection service in the industry. On average, NRS's team of auditors have over 15 years of experience and conduct in excess of 2000 audits per year. No other provider in the industry enhances your audit program with such expertise or scale.
For more information on Audit Solutions, contact us or sign up for a demo today.
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Compliance Technology That Withstands Regulatory Scrutiny
More than just policies and procedures that are updated quarterly, NRS ComplianceGuardian™ is your go-to online compliance portal for the entire firm.
NRS Consultants have created investment adviser, broker-dealer and private fund versions of Guardian so that it meets the needs of your particular firm. Investment advisers and private funds can easily customize the Code of Ethics and track as well as archive the required annual attestation. The IA and PF versions also allow anyone in your firm to report violations — anonymously or not — with the violation report feature as well as use the library of model documents to standardize the forms used within your firm. Add on the new Personal Securities Trading module and the firm can automate the trading oversight required by the code of ethics rule. The broker-dealer version includes RepTracker which allows you to easily track your registered rep licenses and continuing education as well as U4 changes. The add-on Outside Business Activities (OBA) Module lets you maintain a tight approval process for your registered reps. With each version, you can add consulting or education to your subscription to keep up to date with current regulatory trends or to help you with firm-specific questions.
Interested in learning more about NRS ComplianceGuardian? View our video or register for a demo today.
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Differentiate Yourself and Your Firm by Earning the NRS IACCP® Designation
In 2015, many investment adviser compliance professionals are including education in their plans as a way to both help advance their careers and stay-up to date on the current regulatory and compliance requirements and initiatives. Often, a standard reaction of compliance professionals is taking a course when a new SEC rule is released. While this reaction fills an important need, the industry is demanding a more structured and encompassing approach to investment adviser compliance education.
The NRS Investment Adviser Certified Compliance Professional®(IACCP®) Program, co-sponsored with the Investment Adviser Association (IAA), is a professional education program granting the designation, Investment Adviser Certified Compliance Professional (IACCP), to individuals who complete an online and/or in-person instructor-led program of study, pass a certifying examination and meet its work experience, ethics and continuing education requirements.
The NRS IACCP program:
- Provides participants and their firms with a solid understanding of current regulations and rules required for investment advisers, including rule changes mandated by the Dodd-Frank Act
- Provides resources to help strengthen the firm's compliance program and promote continuous learning within the firm
- Encourages candidates to apply what they learn as they learn it
- Signals recognition of advanced compliance knowledge and skill level to help differentiate you from other compliance professionals
- Allows firms that educate compliance personnel to add another cost- and time-effective risk management tool
- Demonstrates the firm's commitment to an educated workforce and a strong culture of compliance
- Helps advance compliance as a profession
- Supports the community of compliance professionals
For those who want to take the first step toward advancing their investment adviser compliance education with a less intensive curriculum, the NRS Investment Adviser Core Compliance Program provides a foundation with focus on the first level of compliance courses. By completing 10 courses and submitting an Ethics assessment, compliance professionals can earn a Certificate of Achievement, which can then be applied for credit in the future toward the IACCP Program requirements. Review the Core Program requirements.
Earning the IACCP designation helps identify you as a committed compliance leader and demonstrates your firm's commitment to compliance. Courses begin as early as January 15th. For more information or to enroll, contact us today.
Save the Date for the NRS Investment Adviser Compliance Symposia and the 30th Annual NRS Conferences:
- San Francisco Symposium June 9-10, 2015: Location TBD - San Francisco, California
- Chicago Symposium July 21-23, 2015: University of Chicago Gleacher Center in Chicago, Illinois
- Boston Symposium August 11-12, 2015: Location TBD - Boston, Massachusetts
- NRS 30th Annual Spring 2015 Compliance Conference May 5-7, 2015: Westin Beach Resort and Spa in Fort Lauderdale, Florida
- NRS 30th Annual Fall 2015 Compliance Conference October 13-15, 2015: Hilton San Diego Resort and Spa in San Diego, California
We are always eager to hear about the specialized topics and forms of content delivery that you and your firm need to stay current, so please keep the suggestions coming.
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Are you prepared for an active regulatory year?
The New Year is the perfect time to review your compliance program, determine if you have any gaps and create and implement a plan to fill in those gaps. The SEC’s 2015 Exam Priorities include a focus on cybersecurity, data analytics, sales practices, suitability of recommendations in client rollovers of company-sponsored retirement plans and risks to retail investors. Last year saw a 20% increase in SEC investment adviser examinations, and 2015 promises to be a very active examination year as well. The SEC has stated that they will conduct “presence” exams of never-examined advisers this year.
The SEC is expected to continue its “broken windows” initiative, focusing on small rule violations, regardless of whether they result in client harm, fearing they may be indicative of larger violations within the firm. Enforcement actions against investment advisers are expected to increase overall, particularly in the areas of “cherry picking,” distribution payments in guise, and financial reporting irregularities.
In light of the active regulatory environment, it is crucial that you review your compliance program, consider any gaps, and develop and implement an action plan. Don’t know where to start? Need help with assessing your compliance program or designing a plan of action for your firm? We can help. Contact us today for more information.