“Not good enough” cost $200,000 in FINRA fines
Purshe Kaplan Sterling submitted a letter of Acceptance, Waver and Consent (AWC), in which it was censured, fined $200,000 and required to advisory agreements, compensation received for investment advisory services, and other information sufficient to determine whether these activities involved private securities transactions.
Worse yet, FINRA said, the firm did not have an adequate supervisory system for the review of performance reports used by its registered persons in connection with outside brokerage services. The firm’s written procedures concerning performance reports did not include any provision for the supervisory review of the contents of these reports. Nor did it conduct any supervisory review of the performance reports used by its registered persons.
Half baked is…
…not enough. You know the regulators expect you to create a compliance infrastructure that keeps up with your members in the real world. It’s not enough to simply collect and store information, you’ve got to have some strategy for oversight. You need a system in place that fully supports reporting requirements; pre-empts the tracking and addressing of compliance breaches; and anticipates regulatory requirements
No one is immune from regulation
If you are charged with compliance, you know you’re facing increased oversight which requires you to juggle more paper, more files, more data. Regulatory compliance requirements are getting more all-consuming and complying can often times feel like an undertaking without end. If your compliance function is under pressure to do more with less, what are the options?