As 2018 comes to a close, it is important that your firm meets its 2018 regulatory obligations and prepares for the upcoming year.
Red Oak has compiled the following checklist to help guide you through the last few weeks of 2018 and verify you’ve covered any and all outstanding compliance issues so your firm ends the year on a high note.
- Given the growing increase in cyber threats in the world today, it is imperative that your cybersecurity policy sets out a plan to protect all necessary information from nefarious individuals. Review your policy to ensure that it is adequate and up-to-date. If you need assistance establishing a cybersecurity program, check out FINRA’s Checklist for Small Firms or give us a call for assistance.
- Business Continuity Plan
- Given the onslaught of severe weather events the United States has suffered this year, it is important to prepare your firm for whatever might come next. Be sure to test your business continuity plan and make adjustments to your plan as necessary.
- Surveillance Analysis
- Review all surveillance reports to identify new risks and developing trends that may be relevant to your firm.
- Regulatory Filings
- Work with your team so that all necessary filings are accurate and have been filed in a timely manner. Be sure to prepare for any additional filing requirements in the future.
- Make sure that you have completed all necessary reports to clients, investors, managers and all others who are subject to your reporting obligations.
- Regulatory Inspection Preparation
- Ensure that you are in compliance with any recommendations from previous regulatory inspections findings and confirm that all representations to regulatory authorities have been adhered to. Verify that your firm is ready for any inspections that may occur in 2019.
- Marketing and Performance Reviews
- Conduct a review of all marketing materials, including books, websites, brochures, pitch books and social media. Verify that your marketing materials are accurate and contain all necessary disclosures and privacy statements. Review the calculations for all performance information that may appear in any marketing materials and ensure that they comply with GIPS best practices. Consider simplifying this process in 2019 by implementing a marketing and advertising review solution.
- Vendor Due Diligence
- Perform your due diligence on all key vendors. Review your policies and procedures to determine if there are ways to better detect risks associated with your vendors.
- Personal Trading Transactions
- Ensure that you are in compliance with Rule 204(A)-1 and that your Code of Ethics is sufficient for your needs.
- Create and distribute your Annual Code of Ethics certification for all employees to complete and return.
- Create and distribute your Annual Holdings reports (for access persons).
- Create and distribute your Annual Outside Business Activity verification.
- Create and distribute your Annual Compliance Questionnaire.
- Compliance Testing
- Ensure that you complete all necessary compliance testing requirements prior to the end of the year.
- Review state registrations/notice filings for de minimis and cancel any unnecessary filings
- Compliance Training
- Ensure that you have provided appropriate compliance training to all necessary personnel.
- Insurance Policies
- Review existing coverage and establish needs for 2019. Determine if there will be a need to obtain quotes from different carriers.
- Compliance Calendar
- Update your 2019 calendar with important review, testing, regulatory filing, reporting, surveillance, training and conference dates to ensure they are completed in a timely manner. FINRA provides firms with a calendar of upcoming deadlines and events on their site that can be accessed here.
- Compliance Budget
- Create your 2019 compliance budget. Take into account all of the above factors, and more, to determine what will be needed to implement any necessary changes to your compliance program and the costs involved.
We help broker-dealers, advisors, investment firms, and hedge funds meet regulatory requirements, improve their compliance programs and increase ROI. We provide customized services to get your firm up and running, on-going compliance assistance, workflow software solutions and much more to keep your compliance program on track.
For more information about Red Oak Compliance software and services solutions, partnership and/or integration opportunities or to schedule a demonstration, please visit us online, email us firstname.lastname@example.org or give us a call at 888-302-4594.