Background Making a decision to start a broker/dealer can be a daunting task where much time and deliberation needs to be applied. Prior to starting the process for the establishment of a broker/dealer, all individuals and entities should ask the following questions: Why do you want or need to create a broker/dealer?; Are there alternatives … read more
Archives for June 2013
Annual Compliance Reviews
Background Broker/dealers and SEC registered investment advisers are responsible for conducting annual reviews of their supervisory controls and compliance programs, respectively. The following paragraphs provide some basic information on annual compliance reviews. Requirements for Broker/Dealers For most broker/dealers, annual reviews are required to be conducted of their: Supervisory Controls; Anti-Money Laundering Compliance Program; Business Continuity … read more
The Advisory Firm that Needs Updated Procedures
Background An investment adviser was in the midst of a SEC audit. The audit had been consuming significant amounts of time. It was clear to the firm and the SEC that the investment adviser would need to revise or create new compliance policies and procedures. The Chief Compliance Officer contacted FIC indicating that his firm … read more