I previously shared the importance of structuring high-performing teams and putting together a resource matrix that consists of activities and the type of skills and personalities needed to fulfill them. In this article, I’m going to delineate the types of resources and how to fill these roles. But first, let me share the three types...Read More

Having worked as a risk and compliance consultant for 19+ years in a wide gamut of companies from large financial services corporations to non-profits, I am sharing my insights on the people aspect of successful projects. First, let’s start with the importance of structuring best-fit teams. Why is it important to structure a best-fit team?...Read More

Let me demonstrate how serious this is to me with a short story. In the summer of 2020, our family experienced two significant losses as a result of the pandemic that is the covid19 virus or the corona virus.  As a result of these losses, we realized that our financial advisors – tax, financial, legal...Read More

If you are a risk and compliance professional in financial services, you know that there is a ton of free information out there to help you do your job. So why would you work with consultants?Read More

Section 205 of the Investment Advisers Act of 1940 outlines requirements for Investment Advisory Contracts. My recent experience with an investment adviser reminded me to not only look at the rule itself but also to look at other’s work and my own experience having reviewed and audited IMAs for applicability and impact. Here is a...Read More

My recent work with a small investment adviser prompted me to look at what would be some areas that an RIA should look out for. Of course, the list can be extensive and can vary depending on the type of clients, products, etc. I found this risk alert from the SEC’s OCIE to be a...Read More

Are you managing a project, be it in compliance, risk, technology or even construction?  It can be overwhelming and challenging to manage the budget given all the information required.  As the project manager, you are likely at the center of it all with clients, stakeholders, management, and the team all looking to you to provide...Read More

This is a recent conversation we had over what broker-dealers can use to help them comply with their annual supervisory compliance requirements. As you know, FINRA 3130 is the annual certification from the CEO certifying that your firm complies with all the rules and regulations.  And, FINRA 3120 requires testing of controls that are put...Read More

What do you envision the process will be in creating the risk assessment tool and who would typically be involved in its development? We will utilize our risk assessment models as a baseline to develop a specific risk assessment for your organization and goals. Before answering this question, let me try to say that the...Read More

Recently, we took a look at FINRA’s May 2020 disciplinary actions and found that there were 3 cases relating to violations of FINRA 5210. Of the 3 firms, fines were from $30,000 to $150,000. The rule provides: “No member shall publish or circulate, or cause to be published or circulated, any notice, circular, advertisement, newspaper article,...Read More