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By: Beverly Fetcko
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Third-Party Marketers: The Federal Regulatory Scheme
Beginning a discussion of third-party marketers requires some definition of what the term means, who may be included and what the discrete functions are that each may provide. Generally, third-party marketers refers to the collection of industry professionals who call themselves “finders,” “solicitors” and “placement agents.” Each serves a separate and distinct constituent base in the investment industry... |
By: Peter Flynn |
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NSCP Annual Meeting – Investment Advisor Session
Regulatory Compliance sponsored and attended the National Society of Compliance Professionals (NSCP) annual meeting October 4 - 7 in Philadelphia. The meeting was well attended and, as always, had a series of experienced and knowledgeable panelists ranging from SEC and FINRA regulators to attorneys and industry consultants. Below are brief summaries of two of the sessions I attended. |
By: Renee Hall |
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NSCP Annual Meeting – Electronic Communications
Regulatory Compliance was well represented at the recent 2009 National Society of Compliance Professionals (NSCP) Annual Conference in Philadelphia. The event was jam-packed with seminars and round-table discussions regarding best practices for all areas of compliance. Renee Hall, Beverly Fetcko, Rich Horgan, Karen Hagan and I attended almost all of the seminars and are happy to be able to share... |
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Differences between NASD Rule 3010, 3012 and FINRA Rule 3130
NASD Conduct Rules 3010 and 3012 and FINRA Rule 3130 form a complementary regulatory scheme for the supervision of member firms. First, NASD 3010 requires the ESTABLISHMENT of a supervisory system and ADOPTION of adequate Written Supervisory Policies (WSP) and Procedures. Under Rule 3010(a) a firm must establish and maintain a system to supervise the activities of each registered representative... |
| By: Greg Sylvain and Kristen Hargreaves
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Labor Department Rejects Allowing Broker Advice on 401(k) Plans
The Department of Labor rejected a change in regulation issued towards the end of the Bush administration that would have allowed brokers affiliated with mutual funds, brokerage firms and other companies that sell investments to provide investment advice to 401(k) participants. “We believe the final investment advice regulation published in the January 21 Federal Register went too far in permitting investment advice... |
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Third-Party Vendors: Compliance Responsibilities
In the broker-dealer industry, third-party vendors are commonly used to conduct many tasks on behalf of the organization. These may include some or all of the following: IT services, office cleaning services, quote providers, AML/OFAC screening, back office compliance/operations, and order management services. It is important to understand the firm’s responsibilities when engaging in relationships with third parties. |
By: Nathan Jodat |
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