The tendency, when times are tough financially, is for businesses to scrimp where they can. An area that always gets a hit is compliance. After speaking with many compliance officers, it is clear that they want to help the firm be compliant, but some owners are resistant to putting dollars towards this effort.
There are ongoing regulatory changes that will need to be added to your written supervisory procedures manual. If you are not staying updated, you are not following the current requirements and can face stiff penalties from FINRA. It pays to consider the very high cost of not keeping your procedures manual updated. It only takes a glance at Notice to Members to see how many firms are fined for inadequate procedures and how high these fines can be. Here is a sampling:
Firm was censured and fined $37,500. “…the firm failed
to establish and maintain a supervisory system and written procedures.”
Firm fined $75,000. “…failed to establish, maintain and enforce
an adequate supervisory system and written supervisory procedures.”
Firm fined $25,000. “…required to revise its written supervisory procedures.”
Firm fined $60,000. “…the firm’s written procedures failed to provide for any
reasonable follow-up and review to ensure that electronic communications were, in
fact, being printed out and reviewed.”
Regulatory Compliance is ready to assist you in making your WSP current and to provide ongoing updates to help keep it current! Please call Karen Hagan or Rich Horgan at 603-434-3594 to discuss how we may help you.
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