WSJ Compliance Officers Survey
The WSJ surveyed compliance officers at large and small companies over three weeks in late August and early September. 90% of compliance officers have experienced new challenges and/ or amplified risks related to COVID 25% said compliance programs have taken a hit during the pandemic 16% said their compliance programs have become more effective. https://www.wsj.com/video/events/the-wall-street-journal-compliance-officer- survey/C0F3B442-8AD2-4B1C-8C10-273E4C426504.html
Regulatory Compliance Solutions Inc.
Regulatory Compliance Solutions Inc.
1120 6th Ave Suite 4049
New York, NY 10036
347-609-3945
Info@RCSI-Group.com
CCOs Budgets Busted?
CCOs are you working on your 2021 compliance budget?
According to the WSJ, the “pandemic has sapped revenue at many companies,
forcing them to cut costs across theboard. Compliance teams whose
responsibilities have grown along with increased regulatory demands over
the past decade haven’t been spared. Some have been asked to trim budgets
and head count while taking on pandemic-related compliance demands,
creating the potential for compliance failures that allow misconduct to go
undetected or unaddressed.”
https://www.wsj.com/articles/coronavirus-poses-an-array-of-new-legal-risks-for-
companies-11600869600
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Succession Planning, a hard conversation for CCOs to have.
10/8/2020 WSJ “Mr. Pence and Ms. Harris didn’t answer a question about whether they have spoken to their running mates about possible safeguards in the event that they become incapacitated and can no longer lead the country. ” The 25th Amendment clarifies the President’s succession plan. Broker dealers and investment advisors have adopted Business Continuity Plans to deal with business disruptions such as natural disasters, cyberattacks, technology failures, etc. Does your BCP include a succession plan in the event the person whose name is on the door is incapacitated? The SEC proposed a new Rule 206(4)-4 in 2016 requiring advisors to have a succession plan. The plan would include details for how the business and client accounts would be handled for an advisor’s incapacitation or passing. The objective was to minimize any potential harm to clients due to the business interruption. The Rule was never finalized, due to COVID, the SEC is currently asking advisors about their succession plan. How would you answer this question “Does your BCP address the continuity of operations upon the death or lengthy incapacity of one or more of its key personnel.” Something to think about.
Do not feed the Phish!
Beware! Broker Dealer Members are receiving emails from “regulation-finra.org” asking them to complete a survey. Note “regulation-finra.org” is not connected to FINRA and firms should delete all emails originating from this domain name. https://www.finra.org/sites/default/files/2020-10/Regulatory-Notice-20-35.pdf
Text Messaging leads to $100,000 Fine by the SEC.
The case is relevant with so many people working from home. How can a CCO be sure employees are using the firm's network for business communications? Jonestrading failed to retain text messages relating to the firm’s business. The WSP restricted employees from conducting business over text message or on personal devices ; employees annually attested to their compliance with those policies. The SEC issued a third-party subpoena to the Firm, it found that employees were using text messages, the compliance department and management knew that text messages were used and text messages were not retained could not be produced in response to the subpoena. Result $100,000 fine. https://www.sec.gov/litigation/admin/2020/34-89975.pdf
10-24-2022
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Blog
Regulatory Compliance
Solutions Inc.
Regulatory Compliance Solutions Inc.
1120 6th Ave Suite 4049
New York, NY 10036
347-609-3945
Info@RCSI-Group.com
CCOs Budgets Busted?
CCOs are you working on your 2021 compliance budget? According to the WSJ, the “pandemic has sapped revenue at many companies, forcing them to cut costs across theboard. Compliance teams whose responsibilities have grown along with increased regulatory demands over the past decade haven’t been spared. Some have been asked to trim budgets and head count while taking on pandemic-related compliance demands, creating the potential for compliance failures that allow misconduct to go undetected or unaddressed.” https://www.wsj.com/articles/coronavirus-poses-an-array-of- new-legal-risks-for-companies-11600869600 companies-11600869600WSJ Compliance Officers Survey
The WSJ surveyed compliance officers at large and small companies over three weeks in late August and early September. • 90% of compliance officers have experienced new challenges and/ or amplified risks related to COVID • 25% said compliance programs have taken a hit during the pandemic • 16% said their compliance programs have become more effective.
https://www.wsj.com/video/events/the-wall-street-
journal-compliance-officer-survey/C0F3B442-8AD2-4B1C-
8C10-273E4C426504.html
Succession Planning, a hard conversation for CCOs
to have.
10/8/2020 WSJ “Mr. Pence and Ms. Harris didn’t answer a
question about whetherthey have spoken to their running
mates about possible safeguards in the event that
they become incapacitated and can no longer lead the country.
” The 25th Amendment clarifies the President’s succession plan.
Broker dealers and investment advisors have adopted Business
Continuity Plans to deal with business disruptions such as
natural disasters, cyberattacks, technology failures, etc.
Does your BCP include a succession plan in the event the
person whose name is on the door is incapacitated?
The SEC proposed a new Rule 206(4)-4 in 2016 requiring
advisors to have a succession plan.The plan would include
details for how the business and client accounts would be
handled for an advisor’s incapacitation or passing.
The objective was to minimize any potential harm to clients
due to the business interruption.
The Rule was never finalized, due to COVID, the SEC is currently
asking advisors about their succession plan. How would you
answer this question “Does your BCP address the continuity
of operations upon the death or lengthy incapacity of one or
more of its key personnel.” Something to think about.
Do not feed the Phish!
Beware! Broker Dealer Members are receiving emails from “regulation-finra.org” asking them to complete a survey. Note “regulation-finra.org” is not connected to FINRA and firms should delete all emails originating from this domain name.
10-24-22
