Independent Consultant
- 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.