Regulatory Compliance E-newsletter – March 2016


Feature of the Month

Realize the Benefits of Automated Bidirectional FINRA Filing with NRS’ cMAX Advertising Review Module

Processing the required filings to FINRA’s AREF system and retrieving the review letters for advertising material are administrative tasks that can consume a great deal of your compliance department’s capacity.  Enable your compliance professionals to spend more time on compliance and risk mitigation activities, and less time on being administrators.

NRS’ ComplianceMAX (cMAX) can do just that with technology that automates the filing of advertising material to FINRA (with Principal approval), and the retrieval of the review letter once it becomes available.  Once the approved filing has been made, your compliance professionals can focus on other activities with the peace of mind that they will be alerted once the review letter has been prepared by FINRA and automatically downloaded to the original filing in cMAX.

Aside from the benefits of automating the filing, the cMAX Ad Review Module provides much more to your firm including:

  • A Foundation Built on NRS Consultant Expertise
  • SEC 17a-4 Compliant
  • A Central Data Repository backed by a comprehensive Business Continuity Plan
  • Flexible Workflow that can be tailored to your firm’s procedures
  • Customizable Form Content to ensure Data Integrity
  • Ability to incorporate Single-Sign-On and recurring imports of User Hierarchy to simplify user access and maintenance

Sign-up for a demo today to find out how NRS can help you take control of your Advertising compliance.

 

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Technology

NRS ComplianceGuardian™ Form ADV Part 2 Brochure Architect

NRS has designed an easy to use tool for firms to facilitate the creation of the required plain English firm brochure and brochure supplements. Our tools are designed to assist firms in meeting compliance requirements and NRS’s Brochure Architect is designed to not only create the firm brochure and supplements, but also to maintain it going forward and to archive prior versions.

Unlike other templates, this tool will allow users to answer questions about the firm and their supervised persons efficiently creating the appropriate plain English language as the foundation of the adviser’s brochures. From there, firms can edit the content to be more specific to their firm’s situation and once completed, the brochures can be saved in any number of formats, including the required text searchable PDF format. 

Register for a ComplianceGuardian Demo today or contact us for more information.

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Education

NRS Education Delivers In-Person Events in Several Cities Throughout the Country

Technology and online education make it possible for compliance professionals to conveniently keep informed on the latest regulatory and compliance developments without leaving the office.  In addition to convenience, what else do compliance officers request most from compliance education? The answer is clear:  Convenient online education  and  face-to-face education.

Face-to-face.  In-person.  Bricks and mortar.  Call onsite education what you’d like. NRS Education calls it an opportunity to spend time, immersed in compliance topics with other compliance professionals and industry experts.

With NRS onsite education, compliance professionals get:

  • The facts – information and implications of new and existing regulations and regulatory examinations;
  • An exchange of ideas on how to maintain a robust compliance program to help keep the firm compliant;
  • An electronic library of material;
  • A network of compliance professionals; and
  • More

Sessions to keep you ahead of the curve on examinations, cybersecurity, ethics, ERISA , AML and more

Participate in discussions on timely investment adviser compliance topics in a classroom setting. 

NRS Education events are designed to meet criteria for continuing education credits for attorneys, CPA/accountants, certified financial planners, compliance professionals, and other financial securities professionals. Earn CLE, CPE, CFP® and IACCP® credits while updating your firm’s compliance program.

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Consulting

SEC Continues Its Efforts to Increase Oversight of Registered Investment Advisers

The SEC plans to increase the number of RIA examiners by almost 20% in 2016.  The increase will be achieved by shifting SEC broker-examination staff to RIA exams and by using a budget increase to hire more RIA examiners.  Congressional appropriators gave the agency a $105 million budget increase — to a total of $1.6 billion — for fiscal 2016.

The numbers make the need for the SEC to grow its examiner base clear.  A decade ago, there were 8,500 SEC-registered advisers with $24 trillion in assets under management. Those numbers were projected to grow to 12,000 advisers with $65 trillion in AUM in fiscal 2016, according to the agency.

The SEC is also currently working on increasing adviser examinations by allowing them to be conducted by third parties.

“There is a good chance the Securities and Exchange Commission will vote by March on a proposal for third-party exams for investment advisors,” said Investment Adviser Association lobbyist Neil Simon.

“The SEC continues to conduct a “limited scope exam” program as an initiative to engage with “the population of investment advisers that have not been examined in ten or more years.”  As the possibility of an SEC visit – either a full-fledged review or a limited scope exam – continues to escalate, being prepared becomes more imperative.

In further attempts to increase its oversight capabilities, the SEC recently created a new office to assist regulators in more closely monitoring investment advisers. This newly-created ”Office of Risk and Strategy” is tasked with the advancement and development of “new tools and techniques” that will strengthen the risk analysis and surveillance conducted by the agency’s Office of Compliance Inspections and Examinations.

Relying on the experience gained from providing customized compliance services and solutions to the financial services industry for  over 30 years, NRS is uniquely positioned and adept at helping firms deal with these, and many other, challenges.

An NRS consultant can work with you to determine how best to be prepared for an SEC visit or how to respond to an SEC request for documents, ensuring that your firm is viewed in the best possible light by the regulator.  NRS understands the “culture of compliance” that the SEC is looking for and can assist your firm in creating or maintaining such a culture. 

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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Participate in discussions on timely investment adviser compliance topics in a classroom setting. Pick and choose individual sessions or attend all days to refresh
your firm’s approach to investment adviser compliance.