By

Laurie Shen
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...
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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?
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Allia Consulting internal audit
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...
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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...
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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...
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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...
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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...
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Allia Consulting Financial Services Risk Compliance
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,...
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In March, 2020, FINRA fined $45,000 and censured a retail broker for lack of procedures to identify red-flags related to low-priced securities trading. Similarly, disciplinary actions were brought against 2 introducing brokers in 2018 where both were fined heavily, over $1M, for not having supervision and oversight of low-priced securities to detect pump-n-dump schemes, and...
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In FINRA’s February monthly Disciplinary Actions report, there were 3 actions related to UITs.  Before we dive into each of these cases and discuss some lessons learned, it’s important to note that UIT’s were in FINRA’s 2018 Examination Priorities.  Listen to our session on some key take-aways or read our transcript below. Hi everybody. This...
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