RRS teamed up with the compliance department of a large regional broker-dealer to review and update their branch inspection plan, and subsequently assisted the firm in implementing the inspection program.
FINRA Membership Process
RRS was engaged by a large financial services holding company to support its compliance and legal team during a corporate reorganization that required filing simultaneous FINRA New Member Application and Membership Continuance for their wholly owned subsidiaries. RRS support and expertise with these processes resulted in the applications being approved by FINRA in less than 4 months.
RRS served as the Independent Consultant for a broker-dealer resulting from an enforcement action by a State SecuritiesAdministrator for various violations, including the use of letters of authorization. Engagement required expertise of operations, supervisory, and compliance policies to conduct the required reviews and prepare the reports as mandated in the enforcement order.
RRS served as the Independent Consultant for broker-dealers resulting from AWCs by FINRA related to their failure to identify Net Asset Value (“NAV”) transfer programs. RRS was retained to review and assess the appropriateness of the firms’ methodology to identify and compensate affected investors, as well as theirwritten restitution plans to compensate qualified investors. Engagement required extensive expertise in mutual funds as well as overall regulatory and compliance standards.
RRS served as the Independent Consultant for a broker-dealer resulting from a Stipulation and Consent Order entered into with a State SecuritiesAdministrator encompassing the firm’s business and compliance procedures relating to the sales, suitability, supervision, and books and records for fixed income sales. The wide breadth of this engagement required experience and knowledge of fixed income products, requirements of regulatory and industry suitability standards, and FINRA advertising rule requirements.
RRS served as the Independent Consultant for a broker-dealer resulting from an SEC Administrative Proceeding related to the alleged failure to adequately establish and implement policies and procedures reasonably designed to prevent the misuse of material, non-public information. This engagement required knowledge and expertise with regard the use of material, non-public information, Chinese Wall practices, general supervision, industry training standards, and email communication firewall procedures.
An RRS team member was engaged as expert witness in a FINRA Arbitration on behalf a broker-dealer for claims of defamation with regard to comments made on the Form U5 filed pursuant to FINRA rules. This engagement required in depth familiarity with FINRA/NASD rules, policies and practices relative to a member’s reporting obligations when completing and filing Form U5.
An RRS team member was engaged by a broker-dealer as the expert witness in a FINRA Arbitration involving selling away by a registered representative, and the issue of alleged failure to supervise on the part of the employing broker-dealer. This engagement required extensive knowledge of FINRA Rules 3040 and 3010, among others.