November Regulatory Updates from Cari Hopsfenperger at Foreside.

Topics include:

• A reminder about the importance of cybersecurity (hygiene, best practices, and vigilance) and to visit CISA (https://www.cisa.gov/cybersecurity-awareness-month) for valuable (and free) resources to help you reduce your exposure to these threats
• NASAA Reports Top Enforcement Trends for 2020:  Precious Metals Swindles, Online Investment Scams, Dodgy Private Offerings, and Self-Directed IRA Rip-Offs
• SEC Regional CCO Virtual Outreach
• DOL Agrees to Back Off on Enforcement of Compliance with ERISA Fiduciary Obligations for Rollover Advice until January 31, 2022
• The 2022 Renewal Program is Underway.  November marks the beginning of the annual renewal cycle for broker-dealers, registered representatives, investment advisors, and investment advisor representatives (IARs)
  FINRA Annual Renewal Overview
  IARD Renewal Program Overview
• FINRA “Encourages” Members to Consider Updating Their AML Programs
• FINRA, NASAA, and SEC Urge Investors to Establish a Trusted Contact to Increase Investor Protection
• Out of Sight, Out of Mind – Advisor Continued to Charge Clients Fees for No Services After IARs Departed
• “Probability of Human Error is Considerably Higher than That of Machine Error” ~Kenneth Appel
• A Precarious House of Cards and a Royal Flush of Violations

Read more here.

October Regulatory Updates from Cari Hopsfenperger at Foreside.

Topics include:

• Mississippi Adopts Model Rule for investment advisor representative (IAR) Continuing Education
• Mark Your Calendars: The IARD and CRD Renewal Programs Have Begun; Renewal Payments Due December 13, 2021:  To get detailed information about the 2022 Annual Renewal Programs, including the complete timeline, payment methods, helpful tips, and FAQs, click the following links:

  FINRA Annual Renewal Overview

  IARD Renewal Program Overview

• Required Reading:  FINRA’s and NFA Notices on Vendor Oversight and Due Diligence
• The SEC Finds Advisors Response to Phishing Attacks, a Day Late and a Dollar Short
• Advisor Experiences the Horror of Failure to Supervise Remote IARs
• Firm Principals Pay the Price for Riskless Principal Trades
• New Technology but Same Old Conflicts
• “Keeping it in the Family” is a Bad Compliance Strategy
• The First of Many Cases on Breach of Duty – IAR Fined and Suspended, and RIA is Punished for Failing to Perform Suitability Analysis

Read more here.

September Regulatory Updates from Cari Hopsfenperger at Foreside.

Topics include:

• SEC Tells Advisors How to Manage Retail Accounts
• Risk Alert – Observations Regarding Fixed Income Principal and Cross Trades by Investment Advisors from An Examination Initiative
• Attention FinOps: FINRA Updates Interpretations of Financial and Operational Rules
• FINRA Adopts New Rule Addressing the Operation of Inter-dealer Quotation Systems
• When Products are This Complicated, Training is Not Enough
• A Day (or a Year) Late and a Dollar Short – SEC Charges 27 Financial Firms for Form CRS Filing and Delivery Issues
• Three Blind Mice – The Latest Trio of Share Class Selection Disclosure Cases
• Classic Example of Suitability Violations Involving Structured Products

Read more here.