Regulatory Compliance E-newsletter – September 2017

Feature of the Month

Steve Jobs once said “There is always one more thing to learn.” For us here at NRS, we might add that “… now is the time to start.”

September kicks off the back-to-school season, and from the kids that board the school bus, to the compliance professional keeping up with evolving regulations, the learning never ends. Today, you might need to learn more about the implications of gifts and whistleblowers. Tomorrow, it could be a refresher on the Investment Advisers Act. The cycle of learning never ends.

Given the current and future changes in the regulatory environment, the key is to select your curriculum carefully against what you need to accomplish; whether it’s refreshing your knowledge, or going for that certification. Make sure that your path in on-going education takes into account:

  • The facts: Each regulation, whether new or existing, has ever evolving implications.  Make sure to select the key courses you need to stay proactively ahead
  • An exchange of ideas: Compliance programs need to be robust. Ensuring that you have a community of people to exchange ideas with, is key to learning how to maintain the line
  • Soft skills: President Theodore Roosevelt said “speak softly, and carry a big stick.” For the compliance professional, this is an appropriate way to look at how to deal with the implementation of an ethical compliance culture.


Back to School with NRS

It’s back-to-school season, so NRS Education is going back to basics and beyond. Through December, NRS has scheduled over 20 online courses and the NRS Fall 2017 Compliance Conference in Las Vegas to help refresh your firm’s compliance program and nurture your compliance career.

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 compliance topics, or want to earn continuing education credits, NRS Education events identify key industry requirements and best practices that effectively support compliance programs in the toughest regulatory environment. – Learn More

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It’s that time of year again!

With the end of the year fast approaching, now is the time to start preparing for your firm’s annual compliance program review.

Investment advisers and broker dealers are required to review their compliance and supervisory policies and procedures. The regulations requires that at least annually, firms ensure that they have an effective compliance program in place which addresses all applicable securities laws and regulations.

The SEC’s continued interest in the compliance program rule means that advisers must be prepared to demonstrate that they have accomplished a thorough, well-documented annual review. To that effect, the SEC has stated that the firm is the first line of defense responsible for taking, managing and supervising risk effectively and in accordance with laws and regulations. If there is a modicum of doubt whether your firm is prepared, then it is critical that you review your compliance program.

In addition, Broker Dealers must enforce a system of supervisory control policies and procedures that are reasonably designed to achieve compliance with applicable securities laws and regulations. The senior management of every broker dealer is ultimately responsible for setting the tone at the top and ensuring that an effective culture of risk management across the organization is in place. Overall, whether you are a broker dealer, or investment adviser, the key is to ensure that you have the right controls in place and that they are operating effectively. Ensuring this will allow you to continue to comply with required regulations and conduct your business as usual.


With over 30 years of compliance expertise, NRS offers solutions ranging from consulting and training to the technology tools to help you successfully run your compliance program and feel confident that you are meeting SEC, FINRA and state regulator expectations. From helping you with testing your policies and procedures, to ensuring that you have the right documentation in place, NRS can be your trusted adviser; helping you stay compliant and succeed. Find out more here.

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BSA Back in the Regulatory Focus

In case you missed our writeup on the FIRE Solutions blog, we talked about how the Bank Secrecy Act (BSA) is back in focus, and how regulators are now placing a higher priority on its enforcement.

With today’s geopolitical climate spurring more focus on money laundering activity related to illegal drug trafficking and terrorist financing, examiners across the financial services industry are scrutinizing industry procedures and verifying compliance during audits.

Regulators are verifying that financial institutions have developed and implemented effective anti-money laundering (AML) procedures that adequately address their business models. Firms can no longer download and file away a cookie-cutter, “one size fits all” AML procedure template from the internet, present it to regulators upon request, and satisfy BSA requirements.

Increased AML scrutiny is also reflected in FINRA’s current licensing exam program. Candidates who sit for principal exams including the Series 9, 10, and 24 must be proficient in policies and procedures that satisfy the BSA. Candidates also need this proficiency for representative exams such as the Series 6, 7, 65, and 66. Furthermore, AML content appears regularly in FINRA’s continuing education curriculum.

Barring unforeseen changes in global events, this heightened attention to money laundering activity and its prevention will remain a priority indefinitely.


If you’re not already on top of your BSA requirements, it’s time to get your ducks in a row. And you can count on FIRE Solutions… we continually update our exam prep and continuing education courses to fully equip our students for their exams and their front-line duties to protect our U.S. financial systems. More about FIRE Series Exams

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Simplify Your Annual Review Process

Believe it or not, summer is over — and now is the perfect time to make sure your firm’s Policies and Procedures are up-to-date and to start working on your Annual Review.

To help, NRS has developed a new integrated task list function in NRS ComplianceGuardian that provides a simple way to assign tasks and track then to their completion.

You start with a customized policies and procedures manual that is automatically linked to a compliance task list that you can assign to individuals or groups within the firm. This can be viewed in a checklist or calendar format where automated email reminders can be set up with one click. The manual content is written and updated by NRS consultants to ensure that your firm meets current regulatory requirements. NRS’s Smart Update technology also protects your custom content by not allowing it to be overwritten unless you so choose and with the new Microsoft Word editor, your changes are continually tracked.

Once you are done updating your policies and procedures, use the integrated Annual Review Tool for investment advisers to assist in the annual review process. This will allow you to document the review, create workflows for taking corrective actions and when done, automatically generate the annual review report. Broker-dealers can also use the model documents and in particular the ‘Annual CEO Certification Language’ document as a guide for completing the annual review.

Learn more about the one tool that manages the annual review process by registering for a demo today.

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