Regulatory Compliance E-newsletter – October 2016

Feature of the Month

NRS Acquires FIRE Solutions

Evanston, IL– October 5, 2016 – NRS, part of Accuity, today announced that it has acquired FIRE Solutions, a leading provider of compliance and education products and services to the broker-dealer community and an industry leader in securities exam preparation. Palm Ventures, LLC is the lead investor in FIRE Solutions along with The Palmer Group. The acquisition is part of NRS’s strategy to provide a comprehensive, single-source compliance portfolio to its clients that will enable them to fulfill their regulatory requirements.

In addition to its state-of-the-art learning management system and industry leading educational content, the FIRE Solutions team, with its deep knowledge and experience for broker-dealers, will be joining NRS. The terms of the acquisition were not disclosed.

The FIRE Solutions products comprise: firm element and other continuing education content; annual compliance meeting; and securities exam preparation solutions to broker-dealers. In the US, there are over 4,000 broker-dealers and almost 640,000 registered representatives who are subject to mandated requirements for education throughout their career. NRS currently re-sells the FIRE Solutions continuing education offering as an integrated solution with its ComplianceMax platform and will incorporate all of the FIRE content in its solutions for broker-dealers and investment advisers.

Click here to read the full press release.


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NRS Technology Solutions Improvements

Our technology team has been hard at work improving our products. Almost every one of our solutions will be getting significant improvements in the next six months. If you use ComplianceGuardian IA Policies and Procedures, ComplianceMAX Ad Review, Audit Technology, Customer Complaints, Disclosures and Attestations, ADV, G&E, or Registration and Licensing, your user experience will get faster, friendlier, and be better looking.

If you use any of these solutions and/or are interested in seeing what we have planned, please contact our Product Team (the people who design your software) to schedule an exclusive preview of upcoming improvements. Contact us via email –

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Help Your Firm Address the Latest Compliance Regulations

Compliance concerns for investment advisers and broker-dealers surface daily – the SEC’s enforcement action citing an unqualified CCO at an advisory firm, compliance failures in wrap fee programs, FCPA violations and FINRA’s fines on the rise, especially for smaller broker-dealers –  to name a few.

For an overview of the many concerns compliance professionals face, take a look back with the SEC Enforcement results FY2016 released this week, and look forward for a preview of the SEC’s 2017 Examination Priorities as presented at a recent Investment Adviser Association workshop in Chicago.

You are likely to have questions about what you read. Attending a compliance conference is a great way to get answers to many of those questions. The upcoming NRS 31st Fall Compliance Conference in Scottsdale, Arizona on November 2-4 offers an agenda that was carefully designed to cover the investment adviser and broker-dealer regulatory landscape and pressing issues on the minds of compliance professionals and regulators. 

Peter B. Driscoll, the first Chief Risk and Strategy Officer of the Office of Risk and Strategy within the SEC’s Office of Compliance Inspections and Examinations, will deliver the keynote address and Dr. Lee McPheters, Research Professor of Economics in the W. P. Carey School of Business at Arizona State University and Director of the school’s JPMorgan Chase Economic Outlook Center, will enlighten and entertain with a special presentation on the economic and political landscape. Plus, 26 regulatory and compliance experts, including representatives from the Los Angeles Regional Office of the SEC, FINRA and NASAA, will open your eyes and ears to current compliance priorities.

Over 25 sessions include the facts and recommendations from regulators and other industry experts to help draft your firm’s blueprint for compliance success in 2016 and beyond.

The NRS Fall Compliance Conference includes the opportunities to network with industry experts, regulators and your peers, meet with exhibitors who are eager to demonstrate their compliance solutions, and engage in a lively environment with a serious purpose.

NRS Education delivers valuable events that help your firm address the heightened demand to incorporate the latest compliance regulations into the firm’s compliance program. Choose NRS, the compliance firm with a 31-year history in the industry, for a productive and engaging conference experience.

Time is short. REGISTER NOW to join industry experts, regulators, exhibitors and your peers.


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Third Party Exams for Investment Advisers

U.S. Securities and Exchange Commission (“SEC” or “Commission”)  Chair Mary Jo White has made a number of public comments indicating that the SEC is considering former Commissioner Daniel Gallagher’s recommendation to allow third-party entities to conduct examinations of registered investment advisers.

This follows recent statements at the SEC Speaks conference in Washington, D.C., by Diane Blizzard, Associate Director for Rulemaking at the Commission’s Division of Investment Management, that her team is actively working on a proposal for how a third-party program could work to improve oversight of registered investment advisers.

The SEC has not yet provided details regarding the anticipated third-party reviews proposal.  Proposed examinations could range from full SEC-type mock exams to more limited engagements in areas of specific concern. Other variables to speculate about include applicable independence standards, frequency of examinations, cost and cost bearers, qualifications of acceptable third parties and SEC’s oversight of those third parties and whether the results of such reviews will be reported to the Commission or simply made available upon request during an SEC examination.

The SEC has noted that the program would not be intended as a replacement for examinations currently conducted by OCIE, but rather serve as a supplement for improving overall compliance by registered entities.   

Despite the current lack of detail, advisers can and should take affirmative steps now to prepare for mandated third-party exams by engaging independent experts to conduct mock audits or compliance program reviews.  It is far better to remedy any issues identified by a friendly partner working for you, rather than under an imposed arrangement under which findings may be required to be reported to the Commission.

If you would like to make sure your firm’s compliance program is sufficient for any potential regulatory scrutiny, please contact us today.


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