Regulatory Compliance E-newsletter -2014 May
Posted On 5/1/2014 1:33:00 PM
Feature of the Month
ComplianceGuardianTM offers New Personal Securities Trading Module
Is your Code of Ethics program ready for examination? Personal securities transactions are a perennial concern of the SEC. However, unlike some areas of compliance that may be subject to interpretation, compliance with personal trading rules can be clearly measured. A manual review process can take hours and this can be error prone.
Our newly created PST Module can:
- Automate Trade Preclearance Reviews and Exception Processing based on the Code of Ethics rule
- Automate Reporting for Annual Holdings, Quarterly Transactions and Initial Holdings
- Create the required Attestations and Automate Archiving
- Manage Multiple Restricted Lists Simultaneously
NRS consultants can be engaged to review your Code of Ethics, monitor exceptions and notify the firm of trends that put the firm at risk. The Personal Securities Trading Module is one of the only solutions that integrates personal trading rules into a Code of Ethics, reviews requests and trades against the rules as well as providing consulting expertise to oversee the process.
Click here for more information or to schedule a ComplianceGuardianTM PST Demo today or contact us for more information.
to commit to enhancing your professional compliance competence. - See more at: http://www.nrs-conferences.com/spring2014#sthash.Q5YY5POB.dpuf
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A Better Continuing Education Solution
The ComplianceMAX Continuing Education Module allows you to confidently construct, implement, manage and report on your firm’s annual continuing education program. You can administer your entire annual compliance program on one technology platform with high-quality course content and make accessing and completing required coursework easy for your covered registered persons. Select from hundreds of online courses authored by regulatory compliance professionals to create a comprehensive compliance program tailored to your firm’s individual needs.
As a core component of the ComplianceMAX application, the Continuing Education Module allows you to design and implement a training solution that meets the specific needs of your organization:
- 130 Firm Element Courses
- 120 Topics for your Annual Compliance Meeting
- 350 Insurance CE Courses
- FINRA eLearning Courses
- Annual Compliance Questionnaire
- Firm Element Needs Analysis
- On-Demand Annual Compliance Meeting
- Double-Dip Insurance / Firm Element
Register for a ComplianceMAX Demo today or contact us for more information.
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NRS Summer Session - Investment Adviser Compliance Symposia
Face-to-face. In-person. Bricks and mortar.
Call onsite education what you’d like. NRS Education calls it an opportunity to spend two days immersed in compliance topics with other compliance professionals and industry experts.
The NRS Investment Adviser Compliance Symposia are held in interactive classroom settings where learning, relevant to the needs of today’s firms and their compliance professionals, is encouraged through:
- A systematic presentation of rules and best practices by leaders in the industry – attorneys, former regulators, and practitioners; plus
- An exchange of ideas among all participants to help apply what is learned to development of enhancements for the compliance function.
San Francisco Investment Adviser Compliance Symposium – June 10 and 11, 2014
Days 1 and 2 - Investment Advisers Act of 1940 A to Z
Chicago Investment Adviser Compliance Symposium – July 22 - 24, 2014
Day 1 - Professional Ethics, Critical Skills for High-Performance Compliance Professionals, and SEC Exams for Investment Advisers
Day 2 - Disclosure (Form ADV Parts 1 and 2, and Investment Adviser Performance and Advertising)
Day 3 - Trading Compliance (Trading Practices, Best Execution, Soft Dollars, Directed Brokerage, Valuation and Trade Errors)
Pick and choose individual sessions or attend all days to refresh your firm’s approach to investment adviser compliance.
Space is limited. Register today!
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Risk Assessments Take Center Stage
The requirement to identify risks and adequately manage them, have been a major talking point in messages delivered by regulators in speeches, Regulatory Notices and interpretive materials, as well as in face-to-face meetings with industry leaders. SEC and FINRA have both been very clear as to how their examiners will be focusing on the level of senior management involvement in firm-wide risk controls. Firms should be utilizing risk assessments as part of their compliance programs to help mitigate identified risks, with a focus on Conflicts of Interest.
In October, 2013 FINRA released its “Report on Conflicts of Interest,” in which it states that “FINRA expects firms to consider the practices presented in this Report and to implement a strong conflict management framework.“
NRS often finds that firms fail to develop a robust mechanism by which they can identify and document all potential risk areas and determining the level of risk presented by each. Developing a formal, enterprise-level, risk assessment process should be a part of every firm’s strategy to mitigate regulatory, market, reputational and business risks. As a best practice, a broker-dealer risk assessment should take into account a review of their Written Supervisory Policies and Procedures (“WSPs”), disclosures, testing protocols, changes to business practices, compensation practices and products/services offered to investors.
Strong supervisory systems and internal controls are the cornerstones for mitigating identified risks, helping to protect both the clients and the firm. NRS believes firms should continually review and assess all risks that could impact their business. Risks must be prioritized, with adequate controls put into effect in order to lessen potential repercussions.
Risk Assessment undertakings are often minimized, performed only once, or initiated only when major changes impact the business. The regulators have made it clear that a sound compliance program is one which inventories risks, on a continuing basis, taking necessary steps to implement a strategy to minimize their impact.
While many firms are capable of performing their own risk assessment, this project is seldom performed in a timely or meaningful manner. NRS Consultants can provide an objective third-party perspective, incorporating regulatory requirements and NRS’s deep knowledge of industry best practices to help firms effectively identify existing and emerging risk areas, offering guidance in the implementation of appropriate controls.
To find out how NRS can help, contact us today.
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