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 A broker/dealer recently faced a $30,000 fine from FINRA because they failed to detect a representative's involvement in an OBA with a medical cannabis company. The representative not only participated in managing and operating the cannabis company but also co-owned it. When a supervisor asked about the representative's involvement in the marijuana business, the representative denied having any knowledge or involvement with the company. Unfortunately, in this case, the broker/dealer mishandled and ignored several warning signs, which raised significant concerns for FINRA. This broker/dealer also dismissed multiple compliance issues when they were identified. According to FINRA, “The firm failed to take reasonable steps to investigate red flags that the representative was engaged in an undisclosed outside business activity and unapproved private securities transactions.” Eagle Eye was developed to tackle the challenge of relying solely on OBA disclosures from your registered representatives. It utilizes artificial intelligence and machine learning to automatically monitor their online presence. This proactive approach helps identify any compliance issues that need to be escalated to higher levels of authority for review, tracking, and documentation until they are resolved.
Moreover, Eagle Eye offers the added benefit of conducting Secretary-of-State searches across all 50 states. This feature allows you to uncover any corporate registrations associated with your advisors, seamlessly integrating the findings into Eagle Eye's workflow, accessible throughout your organization. By leveraging Eagle Eye, you can ensure comprehensive supervision of your registered representatives, effectively mitigate risks, and take proactive steps to address compliance issues. Source: finra.org  Isn't the whole purpose of a vacation to take a break from work? Why should we even need to plan to avoid working during our time off?
Surprisingly, a recent Harris Poll revealed that 66% of Americans admit to working while on vacation, and 42% even go as far as contacting colleagues during their holiday. Many individuals struggle to disconnect from work, whether due to self-imposed expectations or the unwritten rules of their workplace. That's why we've put together these five crucial tips to help you ensure a truly enjoyable and work-free summer vacation. 1. Make a Genuine Commitment to Taking a Vacation Merely going through the motions of booking flights, reserving hotels, and planning out a basic itinerary doesn't cut it. Simply being physically absent from the office doesn't guarantee that your mind and emotions won't still be entangled in work matters. The purpose of paid time off is to recharge and rejuvenate, allowing you to return to work as a more refreshed and productive individual. Embrace the idea that your vacation is meant to be a time away from work, and fully immerse yourself in the experience. 2. Ditch the Guilt. Truly relaxing becomes challenging when your mind is constantly occupied by thoughts of unfinished tasks and responsibilities you believe you should be tending to. Overcoming feelings of guilt associated with taking time off can be challenging, but it's crucial for your well-being. Find ways to minimize guilt by scheduling your vacation to a more opportune time and avoiding critical work periods. Alternatively, consider completing essential tasks before you leave or expressing gratitude to colleagues who cover for you. Remember, you deserve this break, and the guilt will only hinder your ability to unwind. 3. Communicate Early with Colleagues and Managers Don't just block off the dates on your calendar; proactively inform your colleagues and managers about your absence. Send calendar notifications to those who need to plan around your vacation or will be covering for you. It's easy for people to overlook or forget about your time off when they are engrossed in their own responsibilities. By communicating early, you ensure that everyone is aware and can make the necessary arrangements, ensuring a smoother transition during your absence. 4. Set up an "Out of the Office" Auto-Reply Auto-replies work wonders in managing expectations. Configure an "Out of the Office" message for your email and voicemail, informing clients, coworkers, and your boss that you are away and will not be available until your return. This simple reminder alleviates the pressure to respond immediately, enabling others to respect your time off. Whether it's customers, major clients, or your team members, ensure they understand that your focus is on relaxation and rejuvenation during your vacation. 5. Minimize Other Work-related Responsibilities Reducing work-related responsibilities is not limited to your job tasks alone. Many individuals, especially women, find themselves burdened with caretaking responsibilities even during vacations. To truly unwind, plan ahead and enlist the support of babysitters, family members, or partners to help shoulder these responsibilities while you take your well-deserved time off. By addressing these additional obligations, you create the space to fully enjoy your vacation without unnecessary stress. As a full-time employed individual, you work hard throughout the year, often putting in long hours. According to a Gallup poll, full-time workers in the United States spend an average of 47 hours per week on-the-job. Therefore, you deserve a vacation that allows you to unwind and recharge. Remember, vacations don't just “happen spontaneously”; they require thoughtful planning. If you haven't had the opportunity to sit down and plan your summer holiday, it's not too late. Incorporate these tips into your vacation plans and prioritize a truly work-free and then give us a call. Let us show you how our applications will help streamline your supervision processes and ease the burden of piling up workloads after your PTO. The perception of never-ending work is a common experience for professionals in the supervision and compliance departments. At SiteQuest Compliance, we understand this challenge, which is why our applications are equipped with built-in automation features to streamline your workload. EAGLE EYE is always running in the background searching the web. You can customize alerts so that if you are out of the office, alerts can go to another designated person. SQWATCHER will continue to monitor websites, even when you are on vacation. With our easy-to-use workflows, when you return you will be able to go through any changes that occurred while you were away. 5/2/2023
KNOWN COMPLIANCE GAPS I’M SURE I HAVE SOME COMPLIANCE GAPS, BUT DON’T KNOW WHERE TO START...
It can be very challenging for financial firms to search, monitor, and document their advisor's web presence and registered websites without interrupting day-to-day business demands and operations. Yet failure to do so can leave exposed compliance gaps unaddressed and open your firm up to fines and disciplinary actions from regulatory agencies. Common compliance gaps often include improperly documented or improperly enforced policies and procedures, insufficient evidence of a WSP, undisclosed OBAs and social media accounts, as well as rogue advisor websites. Many firms know that they have gaps, but they don’t know where to start. FINRA publishes a monthly disciplinary report with actions and fines against firms and individuals. One of the most common fines involves undisclosed OBAs. Currently, many firms work on the “honor system” with hopes that their employees with be completely honest and disclose everything required. Unfortunately, this honor system doesn’t always work. How are you to find out if your advisors have an undisclosed OBA? That is where Eagle Eye can help you close this gap with our deep web searching technology that quickly cut through the clutter of the web and bring to your attention relevant results when monitoring your registered reps. Do you know if your advisors have disclosed all of their social media accounts? In a recent random sampling of 10 employees from a prospective client, our Eagle Eye solution found serious violations with three of the advisors including several OBAs and social media accounts that were never disclosed. This is a typical compliance gap for many firms. Is this one your firm is facing as well? Are you sure that your firm is monitoring all of your advisors online advertising? Do you have a process in place that is easy to demonstrate to a regulator? Do you even know if they are producing advertising that you are unaware of? This could be another compliance gap your firm is facing. In addition to all of the supervision regulations, you need to prove that your firm has WSPs in place to help document all of the actions your firm is taking to monitor web presence. For many firms, this turns into another compliance gap they need to address. You have a broker-dealer responsibility to monitor every website that your advisors' utilize for business purposes. Many times, advisors want to have their own website to help them stand out among the thousands of other financial advisor websites out there. How are you monitoring these websites? Are you notified of every change automatically so that it can be approved? If not, here is another compliance gap you might be facing, there has been an increase in fines imposed by FINRA regarding website monitoring. SiteQuest Compliance's SQWatcher program is an easy to use solution that will quickly help you fill this gap at a fraction of the cost of a fine. Then to complete all of this monitoring you need to document all of your findings in an organized manner. Many times this is the last step in the compliance process and yet it can become one of the largest compliance gaps for a firm. Our automated documentation features found as part of our programs are detailed and searchable. We provide you with all of the information you need to respond to a regulator. SiteQuest Compliance offers programs, support, and experience to help you bridge these gaps and respond to a regulator. A firm that is able to demonstrate compliance with tangible evidence will mitigate risks, such as costly regulatory fines, and be better prepared for unannounced visits from regulatory agencies. Contact us today and talk to us about any gaps you need help addressing. 2/17/2023
Are You Updating Your WSPs?A firm in Florida was fined for failing to update their WSPs after it began recommending EB-5 investments. Additionally, it was discovered that many of their WSPs were “not deemed reasonable because they provided only limited guidance to those representatives at the firm who facilitated and participated in these EB-5 transactions.” Are you continually updating your WSPs? How do you ensure new policies and WSPs have been reviewed and approved before distributing them throughout your firm?  Oftentimes firms have their policies and WSPs in various pdfs and word documents throughout their system. Many advisors are referencing outdated files saved on the network or their computers. The Policies app from SiteQuest Compliance helps firms organize their policies and written supervisory procedures into one online platform that conveys a professional branded content to their advisors. Policies is a powerful tool used to consolidate, version control, and distribute your firm’s policies and WSPs to your employees and advisors. With our VIP Service included with Policies, SiteQuest Compliance manages all the changes, formatting, and online publishing for no additional charge. Policies notify your employees when a Policy or WSP has been updated. Our “favorites” feature allows advisors to bookmark these new updates for quick reference. In accordance with FINRA rules our Policies application ensures the most up-to-date policies are accessed, identified, and utilized, reducing your risks. This same disciplinary action ruled that “the firm failed to establish, maintain and enforce a system, including WSPs, reasonably designed to supervise its registered representatives’ EB-5 related websites. The firm did not conduct regular supervisory reviews of websites maintained by the two representatives in relation to their EB-5 business that contained content that violated FINRA’s advertising rules.” Our SQWatcher program compliments our Policies application while assisting your compliance department with monitoring your registered advisors’ websites. SQWatcher automatically creates workflow events when website changes have been made, allowing for quick and easy reviews. SQWatcher’s updated dashboard, bulk review enhancements, and powerful workflow review processes allows your firm to monitor and document dozens to hundreds of websites with relatively few employee hours involved. Automated documentation reduces compliance and “failure to supervise” risks while demonstrating to regulators, your firm is actively supervising these unique websites in compliance with FINRA and SEC rules. Contact us today for your personalized demo and see for yourself how SiteQuest Compliance can streamline your processes while maximizing your time and efficiencies. Source: FINRA.org 2/15/2023
Do Google Alerts Work for Supervision? Are you relying on ‘google alerts’ to track advisors’ online presence?
Google alerts are somewhat easy to set up, but are they finding everything? We created our own in-house case study and set up alerts on several team members. As a result, over the last six months, we received about 200 “alert emails” . . . And not one was applicable to any of our team members. Most Google Alerts received are not relevant to what supervision is actually looking for, the primary reason for this is that Google Alerts primarily searches big news sites and blogs. As compliance supervisors, you are looking for information and results usually not covered by mainstream media; these are published in niche industry and regional publications, discussion forums, institute websites, and more. Google alerts require you to add extra characters such as @ and # to help refine your search, but be careful, extra spaces in your alerts can make your searches ineffective. Additionally, it is very difficult to set up alerts if you don’t have a Gmail account. Checking another email account for alerts just adds to your workload. As supervisors’ inboxes become inundated with "email alerts” that have nothing to do with their registered advisors, they may miss important emails from your firm and associates. There isn’t a way to turn off notifications for a specific alert “discovery”. One of our employees has the same name as a contributing author for a prominent news agency. Our email box was alerted daily with her latest article, but this was not the person we were interested in. The only thing we could do was open, read, and then delete these continual email alerts. In addition to the work of going through extra emails, there is the required documentation. Compliance needs to manually copy and paste all the email information and save it somewhere on their network. Hopefully filed logically so that compliance can quickly find it again when requested. This is why Eagle Eye was developed. Eagle Eye eliminates time-consuming, ineffective, manual search processes with easy-to-use workflows and automated documentation. It uncovers and reduces compliance and “failure to supervise” risks while demonstrating to regulators that your firm has a formalized internet supervision program in compliance with FINRA and SEC rules. De-clutter your inbox and stop relying on ineffective alerts. Contact us today for your personalized demonstration and see for yourself how Eagle Eye will improve your efficiencies and support your supervision program. Sources: https://support.google.com/ https://mention.com/en/blog/google-alerts/ https://thefinancialbrand.com/28346/google-alerts-broken/ https://www.contify.com/resources/blog/how-does-google-alerts-work-and-why-it-doesnt/ Do you struggle to keep up with the compliance and supervision responsibilities that require you to monitor and approve the content on registered advisors’ websites?
Other services that monitor and archive websites aren’t built specifically for this industry and their one-size-fits-all approach often leaves compliance overwhelmed without having comprehensive tools, workflows, and processes needed to effectively supervise these sites and meet supervision requirements. What if you could automatically “Watch” all of these websites, identifying specific types of changes that need your attention? Introducing SQ Watcher or “SQWatcher” to our friends. SQWatcher supports your firm’s adherence to regulatory requirements by actively supervising sites for unapproved changes, and providing historical archives of these websites. SQWatcher allows clients to create simple to complex workflows needed to meet their unique and specialized requirements. You can specify the types of changes that generate in your workflows such as new web pages, changes to readable text and images, and much more. Don’t miss Google Reviews, comments, and Youtube uploads associated with your advisors’ business. These workflow items will automatically generate reviews within your customized dashboard. At no extra cost to you, custom-built workflows will organize your reviews into a manageable system that is easy to use, allowing website changes to be shared, escalated, and tracked while compliance issues are resolved within your supervision department. Don’t rely on monitoring services that rely on a one-size-fits-all approach. SQWatcher was made specifically for supervising websites within the financial industry. Contact us today and we will demonstrate how SQWatcher can work for you. 2/14/2022
2022 Supervision Trends There have been many significant changes in supervision over the past 10 years, especially with an increase in workload and scope for online supervision. Trying to stay compliant with the FINRA 3110 Supervision rule can become a daunting task as the web offers an easy to use and often free resources for advisors to get their name and practice out in the public eye. As YOUR compliance partner, we’ve observed several interesting trends that we expect to see increase during 2022. With the increase in online articles being published on blogs, websites, and social media sites like Linkedin, many advisors are writing, being mentioned, and even cited in third party articles. We continue to see these occurrences with very little if any disclosure information and perhaps is not considered pre-approved content. Have you heard of Quora? Quora is an online question and answer platform. 775,000 people use Quora monthly to ask questions. This is a large audience that advisors have the ability to connect with. They can publish content, answer people’s questions, and search for specific topics that relate to your industry. BUT how do you know if your registered advisors are using Quora? Yelp is another online platform that is continually growing in popularity. The Securities and Exchange Commission recently charged three advisers and a marketing firm for violating the testimonial rule by promoting their business on Yelp. Over 4.6 million businesses are using Yelp. With 163 million Yelp reviews, how are you to know if your advisors are actively soliciting testimonials from their clients? Adding to your monitoring struggle is YouTube. It is estimated that over 300 hours of video are uploaded to YouTube every minute! There is an increasing trend in people publishing personal video and vlogs related to their business. With over 1 billion daily users how are you to find videos uploaded to YouTube by your registered advisors if they don’t send you the direct links? Advisors can create non-monitored social media accounts. How do you know if your advisors even have a social media account if they don’t tell you about it? How do you find these social media accounts? One of the biggest trends that we see continuing into 2022 are the use of DBAs. FINRA observed that “certain firms were not maintaining sufficient WSPs and controls, or providing adequate disclosures regarding the use of DBA names.” Outside business activities and unauthorized content from your registered advisors are a growing concern that will always be present. What controls does your firm have in place to aid you in discovering these DBAs if your advisors are not disclosing them? How do you know what your advisors are putting online using their “DBA” name? Your time is valuable. Any search engine can produce an endless amount of meaningless results that need to be reviewed. Our Eagle Eye application is designed with built-in intelligence that sifts through the web’s clutter and brings the most relevant results to your attention. Our multi-query processes and dynamically designed algorithms provide more accurate results for a quick review process. In addition to our search results our automated screenshots feature helps you document, report and escalate any issue that is brought to your attention. One of our clients said : /
"The Eagle Eye Surveillance system has been a force multiplier in my firm’s supervisory scheme. This simple tool has transformed my internet surveillance sweep process from a time-consuming, multi-day enterprise where I view the same search results over and over to a simple process that can be completed in a couple of hours."
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Another one of our clients said: /
“As soon as we implemented Eagle Eye, the system found searches that were previously missed with the manual process and as a result, we updated our policy and procedures to minimize compliance risk. Also, one of our previous hurdles was demonstrating to our regulators with documentation that we were conducting the appropriate monitoring but with the audits reports, that are available directly from the system, we are able to document and show individual findings in an organized manner."
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You can minimize your risk and address these growing trends by utilizing our Eagle Eye application.
Contact us today for your personalized demo of how our application with work for YOUR firm. Sources: https://www.sec.gov/enforce/3-18586-90-s https://www.finra.org/sites/default/files/2018_exam_findings.pdf  When conducting web searches on Google™ or Bing™, how accurate are the results typically? Of course if you’re looking for someone who has a large and prominent web presence, Google searches can be easy. A Google Search on Lebron James will give you plenty of accurate results, but let’s be real. When supervising an advisor, it can be like searching for a single needle in a vast array of haystacks. Eagle Eye’s accuracy for a Broker Dealer client who has used the system for less than one year. Take my name as an example: James Cella. It’s not a common name, BUT there are over 50 James Cella’s in the United States and many of us have a decent web presence. One is a lawyer, another a hollywood film producer while another is a sports information director at a small university. So if one were to try to supervise me and were to Google my name, they would only find 4 results out of Google’s top 50 were actually me. That’s a whooping 8% accuracy. Now one could say that I don’t exist on the web and hence the low results, but the fact is that I do exist on the web with:
So 4 results in the top 50 returned by Google is flat out terrible. Just image how it would look if I were named John Smith. When we released Eagle Eye we set out to design an application that dramatically increased the odds of finding the James Cellas, Sally Jenkins, Timothy Freemans, or whomever our clients needed to supervise. So how are we doing? Overall the numbers are pretty impressive. Our clients generally review anywhere from the top 20 to top 30 results found by the system and they are averaging around 55% to 67% accuracy. One client who has been on the system for nearly a year has an accuracy of 72% in their top 30 and an insane 82% in their top 15. That means that for every 10 results they are reviewing, 7 to 8 of them are the people they are looking for and this is after the company has blacklisted domains they don’t want to review like whitepages.com or classmates.com. How do we do it? We can’t reveal all the ingredients of the secret sauce, but we can tell you that we’ve built complex algorithms and intelligence into Eagle Eye so that it learns as your firm performs reviews. So what does all this accuracy give you?
  Recently I was told by a longtime client that our customer service is “old fashioned, but in a good way”. Perhaps that is the last thing a technology company wants to hear. As president of SiteQuest Compliance, I reflected over what our client meant in that statement. We do pride ourselves on the fact that when you call our office with questions or in need of technical support, that your call is quickly answered by a live person. We don’t force our clients to use service tags, make them navigate unhelpful phone trees, or waste time waiting in queues listening to mundane hold music. We are there for our customers, with a readiness and willingness to meet and exceed their expectations. A compliance supervisor that has been using our applications for several years recently said that “SiteQuest Compliance provides top notch service. They are always happy to hear from me and have exceptional response time. No tickets, bills or painful processes, just a happy voice ready to help.” Another compliance supervisor utilizing our Eagle Eye program said; ‘I deal with vendor support in my day-to-day job. SiteQuest Compliance stands out because they provide prompt service and always take it to the next level to ensure I'm satisfied.” Another one of our clients said that, “I have been using SiteQuest Compliance's Eagle Eye program for almost two years now and have had excellent results. The system does exactly what it was designed to do and we have received excellent customer service from the company. Highly recommended.” We make it easy to contact us with our phone numbers posted right on our website under the “Contact Us” menu header. We enjoy and look forward to our phone conversations with our clients who we know by name and personally as well.
We may be called “old fashioned” when it comes to our customer service, but we accept that name with pride in knowing that it sets us apart from others. Feel free to reach out to me with any questions or web supervision needs that might arise. James Cella President & CEO 801.896.0951 [email protected] 12/27/2021
What we have been up to the past year...This past year we have been busy behind the scenes updating and improving our applications to help increase the efficiencies for our clients.
Our apps are FASTER, FRIENDLY, AND FUN! Ok… work is not always considered fun, but when you improve your productivity and maximize your time, work becomes more enjoyable. WATCH and see what we have been up to. Reach out to me directly at [email protected] for your personalized demo to see how SiteQuest Compliance can support your firm in the coming years. Best wishes for a happy holiday, and a successful new year! James |
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