As the financial services industry has evolved, the supervision of registered persons that are dually registered or affiliated, either with another broker-dealer, an investment adviser or other financial services firm has become increasingly complex. While FINRA speaks regularly about how there is no “one size fits all” approach to compliance, it is clear that supervisory issues related to dual registration have made a standard approach to supervision of these activities an exception. This article focuses specifically on dual affiliations with registered investment advisers. However, note that the concepts related to the supervision of outside investment advisory activities have also been utilized by FINRA to address the sale of variable annuities, promissory notes and the supervision of life settlements. Thus, the same analysis and process should be applied to the approval of any outside business of securities activities.

Daniel LeGaye, Author