The only reason I'm adding this blog entry is that if you landed on my blog and saw the "December Dates" entry, you might think the Patriots were still headed to the Super Bowl. I wanted to spare you that moment of hopeful confusion. It's January and the Pats are going sledding instead. As a Steelers fan living in New England, I have to admit that this shocking turn of events will make for a less hostile mood in the 'hood next weekend. Phew!
Very brief reminders:
If you have to, under the FACT ACT and the Red Flags Rule, make sure you put in place a Written Identity Theft Program. To my knowledge, the rule is now enforceable. Look for my prior ramblings on this topic if you want some background.
If you do annual disclosures in January, such as sending Privacy Notices and information on SIPC and Broker-Check, remember to send them. Also remember that SEC offers a form of model privacy notice, in case you want to switch to a format that will meet their approval. Your existing notice may be fine--but you'll have to review Reg. S-P to be sure. Again, look for my earlier blather on this subject.
Remember, pre-notifcation to and review by a supervisor of all new 'other business' or 'outside business activities' of Reps is now required. Reps can't start doing something new on the side unless this review process has taken place first--and you firms have to document this. And for existing OBA you have until June, as far as I can see, to document your reviews. Start thinking about how you'll do this and getting the documentation in place. If you used a year-end RR questionnaire that solicited this information, use those answers as a basis for requesting and gathering further information on the outside activities.
Don't forget to do a periodic OFAC check of all current customers/accounts. You can define 'periodic.' Put the results in your files.
And remember to encrypt any information you give FINRA on portable storage devices. Notice 10-59 describes this new requirement.
That's it for now. Writing updates to procedures--don't forget to update yours.
Monday, January 17, 2011
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