Regulatory Compliance E-newsletter – April 2017

Feature of the Month

NRS Investment Adviser Compliance Symposia

Attend in-person sessions on topics of current interest to exchange ideas with seasoned instructors and peers in an all-day forum for one or more days. Participate in lecture and discussion-based learning in an interactive classroom.

Whether you are eager to complete a portion of the education requirement of the NRS Investment Adviser Certified Compliance Professional® (IACCP®) or Core Compliance programs, want to sharpen your understanding of individual compliance topics, or want to earn continuing education credits, these in-person education events identify key industry requirements and best practices that effectively support compliance programs in the toughest regulatory environment.

Attending the Symposium helps compliance professionals:

  • Apply the breadth and scope of the Advisers Act and its amendments to help build a strong compliance program that withstands SEC scrutiny and supports the firm’s sustainability
  • Systematically explore compliance requirements for advisory firms of all types and sizes to develop workable solutions for addressing risk associated with registration, books and records, custody, advertising and performance presentation, solicitation and many more compliance challenges
  • Discuss how SEC technology is redefining how data collected from advisory firms is used to assess compliance health, especially in areas of disclosure and insider trading

Don’t miss out on this opportunity to strengthen your firm’s compliance program and advance your compliance career.

 

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Technology

NRS ComplianceGuardian DOL Module

Looking for some certainty within the tumultuous change surrounding the DOL’s Fiduciary Rule? NRS can help.

Our new ComplianceGuardian DOL solution will provide the materials your firm needs to adapt your processes to meet the new regulations. Components include:

  • Policies and procedures
  • Model documents

As change happens, NRS experts will continue to monitor the rule and any best practices resulting from DOL interpretation and make any necessary changes to the model documents, the policies and procedures and tools so that you can be assured that you remain in compliance with any changes.

Register for a demo of the new solution today!

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Education

NRS Named CE Quality Partner by CFP Board

NRS has been named a “CFP Board CE Quality Partner” after successfully meeting criteria established by Certified Financial Planner Board of Standards Inc. (CFP Board).

As a CE Quality Partner, NRS has demonstrated a commitment to developing continuing education (“CE”) programs that meet a high set of standards outlined by CFP Board.  To achieve and maintain status as a CE Quality Partner, NRS agreed to have a random number of self-study and live programs reviewed against a rigorous evaluation rubric developed by CFP Board’s Council on Education.  NRS is now one of only nine CE Sponsors listed on CFP Board’s website as a CE Quality Partner, and is authorized to identify itself as such on its program materials.

A not-for-profit certifying organization, CFP Board owns the CFP® and CERTIFIED FINANCIAL PLANNER™ certification marks, which it awards to individuals who meet its education, examination, experience, ethics and other requirements.  CFP Board currently authorizes more than 76,000 individuals to use these marks in the U.S., each of whom must complete a minimum of 30 CE hours every two years as part of the requirements for renewal of CFP® certification.

The CE Quality Partner program is part of the multi-year CE Quality Initiative that CFP Board’s Board of Directors approved, with the goal of assuring that CFP® professionals have access to a variety of quality CE opportunities that are diverse in their content, format and delivery. CFP Board has implemented several phases of the initiative, focused on improvements to CE standards identified by the Council for Education to better align CFP Board with industry best practices.

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Consulting

Administrative Change and Regulatory Uncertainty Stress Compliance Professionals

An administrative change in Washington and leadership changes at the SEC have hinted at the potential for less regulation and fewer enforcement cases.  On the surface this is a welcome relief to firms.  For compliance professionals this can be a challenging time. 

The benefit of regulations is that they provide certainty and direction.  Most regulations are designed to protect clients and, as such, are aimed at addressing some perceived risk or vulnerability in the service of clients.  Whether it is custody, “pay to play,” DOL Fiduciary Rule, etc., new regulations require firms to go through a process that, in the end, aids in the evaluation of the firm’s operation.  In consideration of a new regulation a compliance professional must understand, identify, determine, develop, educate, and implement policies and procedures to address applicable requirements to the firm.  Existing regulations help compliance professionals assess their activities against some prescribed rule or guidance.

Enforcement provides insight into the application of regulations and the expectation of regulators.  Often more important than laws themselves, enforcement cases, administrative proceedings, settlements, and sanctions all provide both insight into regulatory risks at firms as well as support for compliance program policy and procedures.  For compliance professional, examples of “when things go wrong” can serve as valuable source material for training and education. 

What if new regulation is slowed?  What if enforcement no longer emphasizes “broken windows?”  It will not diminish the need for compliance programs or reduce the workload of a compliance professional.  There will still be ethical considerations and business risks to address.  What it will change is the way investment advisers find direction and support for their compliance programs.    

To relieve the stress of uncertainty that can come from a lack of new regulation and a reduction in enforcement, compliance professional must increasingly rely on their own assessment of risk and perceptions of best industry practices.  Instead of looking to regulations first and then determining risks, compliance professionals will need look at their business activities in identifying risks.  This will require a different set of skills related more toward investigation rather than application.  Beyond the self-assessment, industry best practices will serve as a valuable tool in evaluating programs and assessing expectations.  In the end, instead of looking to a legislature or regulator, compliance professionals may find that uncertainty is best addressed through colleagues, consultants, conferences, and roundtables.

If you would like to make sure your firm is up for existing and yet to come challenges, please contact us today.

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