This blog is by Joanna Belbey, Compliance Subject Matter Expert, Actiance. Follow Joanna @Belbey.
This is a continuation from my blog “FINRA Annual Conference Recap, Day 2 (3 of 5) #FINRA2016” where I share edited versions of my live tweets right from the sessions. As I noted, in the last blog, the recent DOL ruling was a recurring theme, in addition to concerns about culture of compliance and cybersecurity. Here is a recap from FINRA Annual Conference – Day Two.
B2BC: The Do’s and Don’t’s of Record Retention
Afshin Atabaki, FINRA Office of General Counsel, Evan Charkes, Bank of America, Meredith Cordisco, FINRA Office of General Counsel, Harry Striplin, Umpqua Investments
- Folks are still trying to define “business as such”.
- Third parties such as regulators must have access to records.
- You can’t outsource your firm’s responsibility.
- Firms must conduct due diligence analysis of vendors.
- No obligation to store electronic communications to ESM in real time.
- Cloud storage permissible, but records can’t be deleted or overwritten #WORM.
- Firms have regulatory obligation to keep customer data secure.
- Electronic communications and records: big issue that impact everyone.
- Wifi, Bluetooth, VPN all raise concerns pertaining to securing customer data.
- Live Web conferencing treated as public appearance. If recorded, other rules apply.
- Recordkeeping applies to social media. Content is determinative.
Small Firms: Cybersecurity: Threats and Solutions
David Kelly, FINRA Kansas City District Office, Paige Pierce, RW Smith, Joseph Romano, Romano Brothers, Hardeep Walla, Motif Investing
- If your password is easy enough to remember, it’s too weak.
- FINRA is strengthening its own password process.
- Who has access to your assets? Access management is key.
- Secure the applications on your smartphone, laptops.
- Both data at rest and data in transit need protecting.
- Do not click on zip file. #1 rule.
- You will be hit. No question.
- Penetration testing is key.
- Prevention of fraudulent third party wires are significant risks for #Finserv.
- Voice verification is an extra step that may prevent fraudulent third party wires.
Plenary: Compliance and Legal Trends
Robert Colby, FINRA Chief Legal Office, Mari Buechner, Coordinated Capital Securities, Rick Ketchum, CEO, FINRA, John Thiel, Merrill Lynch Wealth Management, James Weddle, Edward Jones
- Clients want to know “Am I on track?” > Jim Weddle, Edward Jones.
- New FAs have expectations to be able to access new tech, including social media > Weddle.
- Committed to bringing in new FAs to offset retiring FAs > John Thiel, Merrill Lynch.
- Millennials will be better informed, educated investors.
- DOL fiduciary rules documents over 1000 pages. Digesting. Mari Buechner, Coordinated Capital Securities.
- DOL: This is not an event, it’s a process. Start by taking an inventory. Mari Buechner, Coordinated Capital Securities.
- New DOL fiduciary rule. Accelerates business model > John Thiel, Merrill Lynch.
Look for updates on other sessions soon.
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