GRC hot topics
Anticipated Behavior Profile
Financial institutions (“FI’s”) are required by Anti-Money Laundering (“AML”) regulations to perform risk-based due diligence for their customers and prospective customer.
- AML and Financial Crime
Calculating Assets Under Management vs. Assets Under Advisement
The SEC has been paying close attention to discrepancies in Form ADV filings, specifically reviewing assets under management. When Annual Updates are due, it’s important to pay close attention to how you calculate your regulatory assets under management (RAUM).
Continuing Education – Regulatory Element vs. Firm Element
FINRA Rule 1250 requires registered persons to participate in Continuing Education (“CE”), with both Regulatory Element and Firm Element training. We break down these categories and how to differentiate them.
Branching Out – Office Registration
When opening a new office in the securities industry, FINRA’s Rule 3110(f) outlines the role of each associated office and registration requirements for each office type.
New FINRA Rule 3210 - Accounts at Other Broker-Dealers and Financial Institutions
FINRA has received approval to update the requirement for disclosure and review of employee brokerage accounts. On April 13, 2016, the U.S. Securities and Exchange Commission (“SEC”) approved Financial Industry Regulatory Authority (“FINRA”) Rule 3210 (Accounts At Other Broker-Dealers and Financial Institutions) to replace current National Association of Securities Dealers (“NASD”) Rule 3050 (Transactions for or by Associated Persons). The effective date for this rule has not yet been determined.