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FINRA Rolls Out Its 529 Plan Share Class Initiative - Is Your Firm Ready to Address It?

Bates News, Compliance and Regulatory Alerts  |  02-01-19

FINRA Rolls Out Its 529 Plan Share Class Initiative - Is Your Firm Ready to Address It?

On the heels of the SEC’s 12b-1 Share Class Initiative, FINRA just announced its own Share Class Initiative. FINRA’s Share Class Initiative sets a deadline of April 1, 2019 for firms to self-report 529 savings plan share class violations and to provide FINRA with a plan to remediate harmed clients.

Bates Group has deep and proven experience and expertise in share class disclosure matters. To support firms facing FINRA’s 529 Plan disclosure and remediation initiative, we have created a plan that provides essential end-to-end steps and solutions to identify and address accounts and clients impacted by share class selection.

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FINRA Highlights Online Platforms, Mark-Up Disclosure & Compliance, RegTech in 2019 Exam Priorities

Bates News, Bates Research  |  01-24-19

FINRA Highlights Online Platforms, Mark-Up Disclosure & Compliance, RegTech in 2019 Exam Priorities

In his latest annual priorities letter to members, FINRA Chief Executive Officer Robert Cook emphasized that FINRA will be monitoring firm developments “to identify risks and assess their prevalence and impact.” He noted that the 2019 letter highlights new areas of focus that will allow member firms to determine whether certain issues “are relevant to their businesses” and how they might be best addressed. In addition, Mr. Cook explicitly stated that these highlighted areas do not affect the ongoing monitoring and enforcement efforts detailed in previous priorities letters. In this article, Bates will review the highlights from FINRA’s newly released 2019 Risk Monitoring and Examination Priorities Letter. We once again list and compare the new priorities to preceding years in the attached Bates’ 2019 FINRA Chart.

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FINRA Announces 2019 Regulatory and Examination Priorities

Bates News, Bates Research, Industry News  |  01-22-19

FINRA Announces 2019 Regulatory and Examination Priorities

FINRA has announced their regulatory and examination priorities letter for 2019.

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Bates Group Welcomes New Expert and Consultant Sheila Murphy

Bates News, Industry News  |  01-18-19

Bates Group Welcomes New Expert and Consultant Sheila Murphy

Bates is proud to welcome Sheila Murphy as a new Expert and Consultant. Ms. Murphy brings over 30 years of legal, insurance, regulatory and retail litigation experience. Prior to joining Bates, Ms. Murphy served MetLife in various legal roles.

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New FINRA Report Details Effective Practices for Broker-Dealer Cybersecurity Compliance

Bates News, Bates Research  |  01-17-19

New FINRA Report Details Effective Practices for Broker-Dealer Cybersecurity Compliance

Right before the new year, FINRA published a report on specific cybersecurity compliance concerns raised in recent broker-dealer examinations. The report provides important guidance for broker-dealers to ensure that their compliance programs adequately address particular risks. Specifically, FINRA highlights best practices among firms on (i) branch office controls; (ii) limiting phishing attacks; (iii) mitigating insider threats; (iv) testing compliance networks for security weakness; and (v) controlling risks related to mobile devices. In this article, Bates reviews these elements and what they may mean for your compliance program.

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Bates Group at the 2019 NYSBA Annual Meeting

Bates News, Industry News  |  01-14-19

Bates Group at the 2019 NYSBA Annual Meeting

Bates is proud to be a Bronze Sponsor of the NY State Bar Association’s Women In Leadership Section Symposium at the 2019 Annual Meeting, Tuesday, January 15 in New York City. Bates Group NY/NJ Managing Director Susan Harper, Esq. will give the welcoming remarks and co-chair a panel. On Wednesday, January 16th, Susan will also participate on the NYSBA Presidential Summit.

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OCIE to Prioritize Protection of Retail Investors in 2019 Examinations

Bates News, Bates Research  |  01-03-19

OCIE to Prioritize Protection of Retail Investors in 2019 Examinations

The SEC Office of Compliance Inspections and Examinations ("OCIE") will prioritize risks to retail investors in this year’s examinations. That concern is a distinguishing highlight of a new report summarizing OCIE assessments of regulatory issues, market risks and policy developments.

Additional featured priorities include continuing risks and concerns related to fee disclosures, share class, and wrap fee programs, anti-money laundering, cybersecurity, digital assets, FINRA and MSRB operations, and issues of compliance by registrants involved in critical market infrastructure. In this article, we review the new report, contrast this year’s priorities with those of the past few years in our annual Bates year-to-year SEC OCIE priorities chart, and consider some implications so that firms might better prepare and, if necessary, adjust their compliance systems accordingly.

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Bates Group Promotes Benjamin Pappas to President

Bates News  |  01-02-19

Bates Group Promotes Benjamin Pappas to President

Bates Group Chief Operating Officer Benjamin R. Pappas has been promoted to President of Bates Group LLC, the leading expert witness and consulting firm for the financial services industry. Bates Group CEO Jennifer L. Stout made the announcement on January 2nd, 2019.

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SEC Office of Compliance Inspections and Examinations Announces 2019 Examination Priorities

Bates Research, Industry News  |  12-21-18

SEC Office of Compliance Inspections and Examinations Announces 2019 Examination Priorities

SEC Office of Compliance Inspections and Examinations (OCIE) has announced their exam priorities for the upcoming year. You can read the press release here.

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FINRA Issues 2018 Report on Examination Findings

Bates News, Bates Research  |  12-13-18

FINRA Issues 2018 Report on Examination Findings

In its second annual effort to highlight areas of compliance concern, FINRA published a 2018 Report on Examination Findings. The thorough report details selected observations and findings from broker-dealer firm exams that have “potential significance, frequency and impact on investors and the markets.” The primary areas of focus in this year’s report are suitability for retail customers, private placements, abuse of the authority a client gives to a registered representative, and fixed income mark-up disclosure. This article takes a closer look at these FINRA priorities and additional FINRA findings on compliance issues raised by this year’s examinations.

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Page 4 of 36 pages.

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