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CEP for CCO's: Dodd-Frank, AML, SEC/FINRA Examinations, E-Communications

March 31, 2011

The SEC and FINRA held the CCOutreach National Seminar for Broker-Dealer Chief Compliance Officers on February 8.  If you couldn't attend, you can still grab their take-aways - as relevant today as they were last month.  For all SEC webcasts, go to:   [SEC Webcasts]

Topical discussions, below, followed welcoming remarks from Mary Schapiro, Rick Ketchum and Carlo diFlorio.

II. Dodd-Frank Legislation (75 minutes - starts at 41st minute)

SEC and FINRA staff discuss the impact of the legislation on broker-dealers, municipal advisors and security swap-based entities.

  • Norm Champ - Deputy Director, SEC OCIE (moderator)
  • James Brigagliano - Deputy Director, SEC Trading and Markets
  • Thomas Selman - EVP, FINRA Regulatory Policy

III.  Anti-Money Laundering Compliance (63 minutes)

SEC, FINRA and CCOs discuss issues related to due diligence and beneficial ownership, independent testing, omnibus and master/subaccount arrangements and direct market access, as well as the challenges associated with building a risk-based AML compliance program.

  • Lourdes Gonzales - Asst Chief Counsel for Sales Practice, SEC Trading and Markets (moderator)
  • Mark Cresap - President, Cresap, Inc.
  • Jeff Halperin - VP, MetLife
  • Joseph Hanvey - Exec. Director, Nomura Securities Int'l Inc.
  • Michael Rufino - SVP and Deputy, FINRA Member Regulation Sales Practice

IV.  Examination Priorities and Process (76 minutes)

SEC and FINRA panelists discuss examination priorities and highlight common findings. CCOs address how their firms prepare for an effective examination and how they use examination results to enhance their compliance programs. Panelists also discuss the custody/asset verification process and expectations.

  • Susan Axlerod - EVP, FINRA Member Regulation Sales Practice (moderator)
  • Thomas Horack - CCO, John Hancock Financial Network
  • Sarah Sherck - MD and CCO, Avondale Partners
  • Joy Thompson - Assoc. Regional Director, SEC Philadelphia Office
  • Kathy VanNoy-Pineda - EVP and CCO, LPL Financial

V.  Electronic Communications (62 minutes)

SEC, FINRA and CCOs discuss compliance considerations associated with electronic communications, including recordkeeping requirements, supervision of social media and advertising review.

  • John Walsh - Chief Counsel, SEC OCIE (moderator)
  • Nathan Headrick - CCO, CNL Securities Corp.
  • Robert Mooney - CCO, Wells Fargo Advisors, LLC
  • Joseph Price - SVP, FINRA CorpFin/Advertising Regulation