Whitepapers

Mock SEC Exams: Benefits and Considerations

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The typical SEC examination will reveal some compliance deficiencies or internal control weaknesses at the firm. When the firm’s compliance or internal control failures are deemed serious, such as when investor funds or securities are believed to be at risk,...

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The Ins and Outs of Outsourcing Compliance

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Compliance is one extremely important element of operating a registered investment adviser (RIA) or broker-dealer, and many financial services professionals fall short in this area. For that reason, firms should decide whether outsourcing compliance is worthy of consideration. As they make this decision, firms should recognize that there are many options available, not just outsourcing the chief compliance officer (CCO) position. In this excerpt from Modern Compliance Volume II: Best Practices For Securities & Finance, Mark Alcaide explores how outsourcing can benefit RIAs and broker-dealers.

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What Are a FINOP’s Real Duties?

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Most people think that a Financial and Operations Principal (“FINOP”) deals only with filing FOCUS reports and/or computing net capital, but a FINOP is so much more. Rule 10221 requires that all broker-dealers have a FINOP and sets forth the registration requirements for persons in this role. In addition, rules relative to the registration of certain officers of a firm state that the broker-dealer must designate a Chief Financial Officer (“CFO”) and that the CFO must hold a FINOP registration.

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The Cybersecurity 2 Initiative

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On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert detailing examiners’ latest findings regarding cybersecurity. During OCIE’s Cybersecurity 2 Initiative, examiners focused on firms’ written policies and procedures relating to cybersecurity and how they were validated and tested. In this article from Practical Compliance and Risk Management for the Securities Industry, Les Abromovitz explores the best practices for cybersecurity policies and procedures that firms are implementing.

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