Compliance Considerations for Dual Registrants
Course Description: Firms that operate both as an investment adviser and broker-dealer have complex business and compliance issues and face the unique challenge of dealing with two or more regulatory authorities. Dual registrant’s sales practices, conflicts and compensation raise difficult issues not present in a stand-alone advisory or brokerage firm.
Compliance professionals need to be prepared to be examined by both the SEC and FINRA. They must manage the differing requirements of investment adviser and broker-dealer regulation as they relate to; fiduciary standards, trading, contract and disclosures, compensation, advertising, recordkeeping and custody and many other potentially troublesome issues. This seminar will highlight areas that you must focus on and will offer concrete and practical recommendations to avoid regulatory problems.
After attending this course, attendees should be able to:
- Examine the keys to conflict management through disclosure and internal management which are inherent in the dual registrant business model.
- Distinguish the key differences in broker-dealer and investment adviser regulation and the areas where there is a need for dual sets of policies for certain personnel, records and activities.
- Analyze trading compliance issues including principal and cross trading.
- List the best execution and disclosure ramifications related to the use of affiliated brokerage for executing trades in advisory accounts.
- Implement best practices for supervising dual employees operating within different systems and subject to different recordkeeping requirements.
- Identify the different regulatory roles of the SEC and FINRA.
- Anticipate the potential impact of new fiduciary standards for broker-dealers and harmonized regulation of investment advisers and broker-dealers.
For Whom: Designed to increase the professional competence of dual registrants (investment adviser and broker-dealer) professionals with legal, compliance, technology and management responsibilities
Suggested Skill Level: Intermediate
Instructional Method: Group-Internet-Based
Pre-requisites for participation: No advance preparation or prerequisites are required.
Advance Preparation: None
Continuing Education Credits
NRS Continuing Education Guide
Recommended CPE Credit: 2 in the Regulatory Ethics field of study
Recommended IACCP® CE Credit: 2
Recommended CA MCLE Credit: 2
Recommended CFP® Credit: Pending