by Karen A Steighner and Philip Feigin
FINRA Rule 3120 testing and verification and the certification required by FINRA Rule 3130 are each required to be completed once each calendar year. FINRA members must submit a report no less than annually to the firm’s senior management containing details of its system of supervisory controls and the results of the testing and verification of those controls. Furthermore, the Rule 3130 Certification must also be completed annually but not later than the anniversary date of the previous year’s certification. New FINRA members are required to conduct the first Rule 3120 testing and Rule 3130 certification within 12 months of becoming a member.
SEC Rule 206(4)-7 requires advisers to conduct an Annual Review to determine whether the firm’s policies & procedures are reasonably designed and implemented to prevent violation of federal securities laws (adequacy testing) and are effectively operating to prevent compliance problems, identify problems that occur and promptly correct those issues – achieving the goals as intended (effectiveness testing).
…Compliance Advisers’ Blue Ocean Strategy for Providing Regulatory Compliance Consulting Services in the Future
Experience the independence of running your own securities compliance consulting firm with access to the support, resources and expertise of a highly successful brand – Compliance Advisers, Inc.
Currently, we are launching a new initiative – Strategiance™ to grow and enhance our long history of providing customized compliance solutions to the securities industry. A valuable component of this initiative involves expanding our network of executive compliance consultants with securities industry experience who are looking to build their own successful compliance consulting practice. We offer expert guidance, support and the necessary tools designed to help independent contractor consultants achieve success and a rewarding career. As an independent consultant, you will have the opportunity to work for high-payout, commission-based compensation using our successful Compliance Advisers brand and proven platform, bonus and stock option programs, and other benefits.
For more information about how to become part of our Strategiance™ initiative, click here.
By Karen A. Steighner, MBA
In spite of the seemingly never-ending stream of new regulation in the financial services industry, failure to be aware of heightened regulatory concern and not developing an effective Cyber Security program is particularly problematic for broker dealers, advisers and other securities market participants. The consequences of not doing so not only leave the firm particularly vulnerable to the devastating effects of a cyber attack, but also to a regulatory violation—twice the trouble. Dealing with the expansive and expensive damage resulting from a cyber attack is two-fold and substantially more onerous than actually developing and implementing an effective plan.
We are excited to announce that our CEO, Karen Steighner, is a member of Women in Compliance.
Compliance Advisers conducts full, comprehensive Cybersecurity Risk Assessments to help Firms identify and analyze potential dangers or risks to its business that could arise through its information technology systems.
The most comprehensive, all-inclusive registration package offered in the industry…we specialize in managing the entire process for you.
New Broker/Dealer Registration-The expert staff at Compliance Advisers assists its clients through each step of the application process–from developing your customized Business Plan according to FINRA guidelines & unique to your business