Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
On March 17, 2022, FINRA issued Regulatory Notice 22-10 (“Notice”), which reminds FINRA member firms and their associated persons of the scope of supervisory liability for Chief Compliance Officers (“CCO”). The Notice...more
Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials. On March 17, 2022, the...more
The lack of specific guidance regarding failure to supervise liability for chief compliance officers (“CCOs”) has been a controversial and opaque topic that both FINRA and the SEC have struggled with for well over a decade....more
FINRA recently published Regulatory Notice 22-10 reminding firms of the scope of Rule 3110 (Supervision) and the potential liability of Chief Compliance Officers for failure to reasonably discharge supervisory...more
In this Issue. The Financial Industry Regulatory Authority (FINRA) issued a reminder about chief compliance officer (CCO) supervisory liability under FINRA Rule 3110 (Rule 3110); and the Consumer Financial Protection Bureau...more
Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more
A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more
We have frequently blogged here about the degree of attention that regulators pay to Chief Compliance Officers, and whether it is proper that they sometimes are named individually in Enforcement actions. And we are hardly...more
A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more
In This Presentation: - What is “Supervision”? - CFPB’s Examination Principles - Supervision is a Process - Types of Examinations - Preparing for the Examination - EXAM PROCEDURES ...more