ANNUAL CERTIFICATION FOR PERSONNEL
Personnel are required to complete a Compliance Certification Form annually to update information found on SEC Form U-4 and other compliance records. Compliance Administration will dispense the form to individual(s) and track the return of the form. If a change to Form U-4 or other records is required, we will amend and update each individual’s records accordingly.
ANNUAL RENEWAL OF BROKER-DEALER & REGISTERED REPRESENTATIVE REGISTRATIONS
Annually, every broker-dealer must renew the registrations of the broker-dealer and all requisite personnel with the Financial Industry Regulatory Authority (FINRA) and with every state in which he or she conducts a securities business. Compliance Administration will confirm the selected states and determine the amount of funding needed for the WebCRD account to cover both the firm and the individuals. We will then execute the renewal. Compliance Administration will notify the firm when the preliminary statement is available to view in November.
CONTINUING EDUCATION TRAINING PLAN PREPARATION AND IMPLEMENTATION
Our team will distribute a Needs Analysis Survey to all representatives and supervisors, track the receipt of the surveys, and review the findings of the survey. A Training Plan will be prepared and updated to reflect the training needs of the firm based on the results of the survey each year.
FIRM ELEMENT TRAINING AND TRACKING (COST OF TRAINING IS ADDITIONAL)
After compiling results from Needs Analysis Surveys, Compliance Administration will recommend appropriate Firm Element and anti-money laundering (AML) training materials. Compliance Administration will provide access to training from a list of courses containing subject matter germane to the needs of the firm. Compliance Administration will monitor and track your employees’ progress to ensure the annual Firm Element requirement is met. The training materials selected are provided at an additional cost.
REGULATORY ELEMENT NOTIFICATION AND TRACKING
Progress will be tracked using WebCRD to open “windows” for exams and to notify each employee when his or her window opens for required Regulatory Element Training. We will notify your Compliance Officer and/or firm supervisor when training is complete. Omission of required Regulatory Element Training can result in the termination of a Rep and a possible censure and fine from FINRA.
EMPLOYEE PERSONAL TRADING RECORD KEEPING
Compliance Administration will prepare permission letters in order for your employees to maintain personal trading accounts. We will also request duplicate account statements for each account. The account statements may be maintained at your office or the Compliance Administration office.
MONITORING AND UPDATING OF FINRA GATEWAY AND WEBCRD
Our team will review and monitor your firm’s FINRA Gateway information, FINRA Contacts System, and WebCRD record for deficiencies. We will also track and make any routine updates.
QUARTERLY COMPLIANCE MEETING PRESENTATION TEMPLATE
After initial consultation, we will help to create specific agenda items relevant to Firm policy, regulatory rule changes and new compliance issues to incorporate into your firm's Annual and/or Quarterly Compliance Meeting. Our team will also prepare talking points to help facilitate the meetings.
BUSINESS CONTINUITY PLAN: ANNUAL REVIEW AND UPDATE
Compliance Administration will prepare, review, and update your firm’s Business Continuity Plan, incorporating any key changes in the plan or relevant SEC Rules to meet FINRA’s annual requirement.
FIDELITY BOND RENEWAL
Annually, Compliance Administration will prepare, review, and update your firm’s Fidelity Bond Renewal incorporating any necessary changes (i.e. that firm changes satisfy regulatory requirements regarding coverage). The team regularly reviews FINRA’s fidelity bond requirements and will ensure that your firm remains up-to-date.