FINRA’s 2021 Report on Examination and Risk Monitoring found that with regards to Rule 2210, Communications with the Public, many firms had insufficient policies, supervision, and recordkeeping for their digital communications.
FINRA reminded firms that a “digital communication policy must address all permitted and prohibited digital communication channels and features available to your customers and associated persons.”
Our new Policies solution will help ensure that your registered advisors are utilizing your firm’s most current and up to date policies and WSPs with regards to Communications with the Public. Advisors can even designate these Rule 2210 specific WSPs as “favorites” for quick and easy reference within the Policies app.
FINRA also reminded firms about the need to provide training on relevant FINRA rules and firm policies when it comes to communications with the public. With our Policies app you can send links to your advisors when new policies are published. Each policy will state when it was published and by whom. You can even link within your policies to specific related FINRA regulations and rules.
FINRA cited as some of their concerns: “Not maintaining policies and procedures to reasonably identify and respond to red flags—such as customer complaints, representatives’ email, OBA reviews or advertising reviews—that registered representatives used impermissible business-related digital communications methods, including texting, messaging, social media, collaboration apps or “electronic sales seminars...”
SiteQuest Compliance has several applications to support compliance personnel in their efforts to supervise “Communication with the Public”.
Our Eagle Eye app will assist you in monitoring the internet while discovering any potential undisclosed OBAs, social media accounts, blogs, websites, and more. With built in automated documentation you will have everything you need including when a result was found, who reviewed it, comments that were made, and timestamps on every action taken. From a regulatory point of view, with Eagle Eye you will have the full story of what communication content looked like at the time of review, giving you everything you need to respond to a regulator.
Eagle Eye's “Heightened Supervision Mode” empowers you to monitor your advisors at a variety of levels. For those that push the envelope a Heightened Level of Supervision may be required. In any situation, Eagle Eye allows you to customize your approach with built in automation to notify specific individuals up the chain of command.
FINRA stressed the importance of notification and monitoring. “Requiring registered representatives to notify compliance of any changes to approved communications, and conducting periodic, at least annual, monitoring and review of previously approved communications for changes and updates.”
With our SQWatcher application, firms can monitor communications on websites by actively supervising for unapproved changes and providing historical archives of the sites. SQWatcher can even monitor websites hosted by non-approved website providers.
SiteQuest Compliance supports your firm’s adherence to regulatory requirements 2210 by actively supervising the internet, monitoring and archiving websites, and ensuring that your advisors have access and are utilizing the most current policies and WSPs with regards to Communications with the Public.
With our suite of compliance applications SiteQuest Compliance has become a trusted partner for over a decade. Contact us today and see for yourself how our suite of applications will work for you.
About James Cella
James Cella is the President of a growing and innovative compliance technology provider called SiteQuest Compliance. James is a customer-centric individual and focuses on building and sustaining positive and lasting relationship with his clients and partners. James and his family are "super fans" of University of Utah Football and have attended nearly every home game since 2002. Go Utes!