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Eagle Eye, by SiteQuest Compliance, can now search across all 50 states for corporate registrations associated with your advisors. Click to watch and see how.
These Secretary of State reviews are integrated into Eagle Eye’s workflow and can be reviewed with other items of concern such as undisclosed social media accounts, online profiles, websites, event listings, and more. Additionally, corporate registrations can be reviewed in a customized workflow allowing you to view findings across your organization. Eagle Eye automatically documents the whole review process with details on what was reviewed, who reviewed it, comments and actions taken, complete with timestamps, and a screenshot of the business registration listing. Contact us today for your personalized demo to see how Eagle Eye can help you save time and money while lowering your risks associated with Outside Business Activities. 9/20/2021
PART TWO OF NATIONAL PREPAREDNESS MONTH Continually Making Sure Your Monitoring Records and Documentation are in Order
This is not a preparedness matter to take lightly. Just last November FINRA fined a Tier One Company $2.6 million for failures in required electronic records and email retention. Read the full report. The benefits of maintaining accurate, reliable and usable records can help to increase the efficiency and effectiveness of your business. It will ensure your firm is able to access information when required and meet all accountability and compliance requirements. Below are some suggestions that are beneficial in establishing and making sure that an effective record keeping and documentation system is in order when you are monitoring your associates' web presence. Planning. Establish what processes are needed for monitoring records to be effectively maintained and how this will be achieved. Planning a monitoring process will help you maintain a record keeping system that works for your firm and provides clear expectations for supervisors and compliance officers. Consistency. To make it easier for compliance staff members to do their job, have information collected and stored in a consistent way within your firm's network; all staff should follow the same policies and procedures. Communication. Have all your staff made aware of, and ensure they understand, the FINRA general supervision requirements. Verify that all supervisors know and follow the record keeping policies and procedures established by your firm. By communicating expectations clearly, you will benefit from consistent record keeping standards. Modify. Don’t be afraid to modify your record keeping system if you find a more efficient way to achieve results. Regular reviews of your record keeping systems will keep them up-to-date and operating in a way that is beneficial to your firm. Responsibility. Know your responsibilities—what to record, how to maintain records and how long they should be kept. Having accurate and reliable records during an audit will allow you to easily confirm your firm’s compliance. Review. Encourage staff to provide feedback on how the monitoring record keeping system is working and how it could be improved. In doing this, you may gain valuable suggestions that will bring continuous improvement to your administrative records, improving the efficiencies of the practice. Embrace technology. Regularly investing in technology will help improve the efficiency of your general supervision monitoring requirements. Your staff will appreciate any efforts made to improve and automate the task of keeping records, giving them additional job satisfaction. Additionally, removing manual steps not only makes the record keeping process more efficient, it also makes the records uniform and reduces the risk of human error. Our clients have found that Eagle Eye’s automated reporting features saves them valuable time. With just a click, you will have everything you need including when a result was found, who reviewed it, comments that were made and time stamps on every action taken on the account. From a regulatory point of view, with Eagle Eye’s automated screenshots you will have the full story of what content looked like at the time of review, giving you everything you need to respond to a regulator. Supervising the web doesn’t have to be difficult! Let us show you how Eagle Eye is a more effective solution. Contact us today for a demo. Does your web supervision program completely hinge upon disclosure from your advisors, employees, or clients? As the web continues to grow, new technologies create more and more opportunities to advertise, promote, and engage with prospective clients online. These increasing requirements to uncover and supervise a representative’s web presence falls upon compliance and supervision departments. That is where Eagle Eye provides a solution to help formalize your internet supervision program while lowering your risk. Watch and Learn More. Contact us today and let us demonstrate how Eagle Eye can support your compliance department.
9/1/2021
ARE YOU PREPARED FOR AN AUDIT? Did you know that September is National Preparedness Month? Emergencies can happen at anytime and anywhere. Ready Business is a resource that assists businesses in developing a preparedness program by providing tools to create a plan that addresses the impact of various hazards. Preparedness is the key to ensuring that your business will continue after a disaster.
In light of this national observance, our blog is focusing on preparedness and preparing for an audit. We understand that the arrival of FINRA examiners at your firm may cause some concern—especially if it’s your first examination, or if it has been a while since your last audit. How can I help my firm prepare for a FINRA audit? Tell your staff about the audit. This also helps those staff members that FINRA needs to contact, identify and prepare the records and information that they need to have available when the audit begins. Review past audits. If your firm has been audited in the past, it is worth reviewing the last audit report. Often past audits have recommendations for improvements. In conducting routine audits, FINRA’s purpose is to identify opportunities for improvement, which are in the best interests of the firm being audited and their clients. Identify an audit contact person who can act as a liaison person to work directly with the auditor. This staff member should be responsible for ensuring that auditors have access to records and files or any other resources needed to complete the audit. This person acts as the main point of contact as the audit progresses so that FINRA can continue to keep your firm informed of how the work is going. Your firms’ contact person may find it useful to schedule meetings with FINRA periodically throughout the audit process to help monitor how things are progressing. This is a good way to facilitate communication, resolve issues on a timely basis, and correct any misunderstandings. Cooperation is essential to a successful audit. Depending on the type of exception, if your firm can demonstrate swift corrective action, it may not appear in the final Examination Report. Assemble appropriate and current information about your firm that you think might help FINRA in gaining an understanding of your administrative structure, nature of your operations, and knowledge of employee roles and responsibilities. Other information that might be helpful to have on hand could include key procedures or policies, organization charts and financial information such as budgets and sample management reports. Hot Topics. FINRA is really focusing on social media and cyber security preparedness as part of their audits right now. Are you prepared to respond (with proper documentation) to a regulator when they inquire with regards to your supervision preparedness? Are you finding everything that you are required to monitor? Do you know for certain that your employees have properly disclosed all OBAs? Being prepared to address these "hot topics" will help in the event that you are audited. A FINRA audit is an excellent opportunity to take a thorough look at the risks impacting your business and the controls put in place to mitigate those risks. Please note that these are only general steps recommended to prepare for an audit. We recognize that specific steps and information requests that are unique to your firm will be identified and communicated to you as you interact with auditors. Source: FINRA.org 6/28/2021
Communications with the Public 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. Source: https://www.finra.org/rules-guidance/guidance/reports/2021-finras-examination-and-risk-monitoring-program/communications-with-public  Isn’t the whole point of a vacation not to work? Why would you have to make a plan not to work?
According to a recent Harris Poll 66% of Americans report working when they take PTO or vacation days. 42% admit to contacting a colleague while on their holiday. Many of us simply cannot unplug from work. Whether self-imposed or an unwritten rule of your workplace, employees are not taking the vacation time they need and deserve. That’s why we’ve put together 5 tips on how to ensure your summer vacation is as enjoyable and work-free as possible. 1. First, make a real commitment to actually taking a vacation. Going through the motions of buying airplane tickets, hotel reservations, and drawing up a basic itinerary doesn’t count. Just because you’ve made plans to not be physically present in the office doesn’t mean you are not mentally and psychologically still wrapped up in your work. The whole point of paid time off is to rejuvenate and recover. You simply can’t be your professional best if you don’t take time off. So get into the mindset and buy into the fact that your holiday is supposed to be time away bringing you back to the workplace as a better, more refreshed person. 2. Ditch the guilt. You can’t relax if you’re worried about what you’re “not” doing. However, it’s easier said than done for some of us to not feel guilty about taking time off. Do what you need to do in order to minimize feelings of guilt. For some of us that may mean rescheduling a vacation to a better time (e.g. not in the middle of a new product launch) or trying to cram in your tasks before you leave. For others, that may simply mean taking a colleague out to lunch to thank them for covering for you ahead of time, or sending them a treat when you come back. 3. Communicate with your colleagues and managers early on about your absence, and don’t just block the time on your calendar. Be sure to send calendar notifications to those you think really need to have this planned into their own work schedule because they will have to cover for you or simply need to be aware. Everyone is busy and it’s hard for people to be aware of anyone else’s schedule. Many of your colleagues want to respect your time off but simply don’t remember or don’t realize that you will be gone. 4. Create an “Out of the Office” auto-reply for your email and your work voicemail. Auto-replies work. Customers and co-workers will understand that you will not respond till you are back from your vacation. They just need a reminder that you are away. In some cases, your boss will be the one that needs a reminder, or it may be your major clients or regular contacts. In other cases, it’s simply telling the team-members who will be covering for you to be proactive in cc:ing you (or not, if you prefer) but not expecting you to respond. Doing this may not reduce the number of emails or voicemails you return to, but it will set expectations and explain why you are not responding for a while. 5. Minimize your “other” work on vacation. Your job responsibilities are not the only kind of work that you should try to minimize on vacation. For many women, care-taking responsibilities surge to the forefront on vacation. Just ask any mother and she will tell you that childcare and family responsibilities on vacation can be so exhausting that it’s more restful to actually return to work. Making a plan to enlist babysitters on vacation, family members, or partners for their support while you're taking time off is something many individuals neglect to do. If you’re like most full-time employed Americans, you work hard. According to a Gallup poll, adults employed full-time work reported working an average of 47 hours per week. You deserve a vacation and they don’t just “happen” without some active thought and planning. For many in the supervision and compliance departments they feel like their jobs are never ending. That is why we have built in automations for our applications. Eagle Eye is always running in the background. You can customize alerts so that if you are out of the office alerts can go to another designated person. From a regulatory point of view, Eagle Eye will give you the full story of what content looked like at the time of review, even if you are out of the office, giving you everything you need to respond to a regulator. SQWatcher will continue to monitor websites, even when you are on vacation. With our easy to use workflows you will be able to go through any changes that occurred while you were away. Our easy to use workflow feature sets SQWatcher apart from the competition. Reviewers can identify what has changed on the website, where changes occurred, and when the changes happened. Our content ignore feature gives you the ability to ignore sections of the site that generate unnecessary reviews like stock tickers, date widgets, and more. Saving you countless hours. It’s just the beginning of June so if you haven’t had the chance to sit down and really plan your summer holiday yet, make sure your vacation plans incorporate these ideas. Then give us a call and let us show you how our applications will help streamline your processes and ease the burden of piling up workloads after your PTO. 3/15/2021
Time is Your Most Valuable Asset There’s a reason why most successful people agree that time is their most valuable asset: Once it’s gone, it’s gone forever. Unlike money, you can’t earn more time. Here are five ways how I try to get time back during my workday:
In business in general we waste our time by doing what we have always done, the way we have always done it. Getting bogged down in manual processes that could be streamlined through innovation and technology. Oftentimes for compliance, their responsibilities can become overwhelming, frustrating, and stressful because the workload for supervision is continually multiplying. Today’s regulatory environment is one that supports innovation within the financial industry. Regulators encourage financial organizations to rely on technology to effectively and efficiently execute a compliance program. FINRA’s newly formed Office of Financial Innovation is an example of this. For over a decade SiteQuest Compliance has been the partner of choice when it comes to internet supervision and website monitoring. Our automated applications on average cut our clients work load by 80%. Eliminating time-consuming manual processes, automating notifications and reports, and streamlining workflows. How do you want to get back your time? Contact me today, and I will personally show you how our applications will work for you and your firm. One of our clients stated: "The Eagle Eye application 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." 2/26/2021
Compliance with FINRA Rule 2210 The “Communications with the Public” Rule FINRA 2210 states that “an appropriately qualified registered principal of the member must pre-approve each retail communication before the earlier of its use or filing with FINRA's Advertising Regulation Department ("Department").”
“Retail Communications” include all electronic formats as well. In addition to supervision approval: “Each member shall establish written procedures that are appropriate to its business, size, structure, and customers for the review by an appropriately qualified registered principal of institutional communications used by the member and its associated persons. Such procedures must be reasonably designed to ensure that institutional communications comply with applicable standards.” Our Eagle Eye and SQWatcher applications support your compliance program when it comes to complying with this rule. Our innovative Eagle Eye application will search the internet and allow supervisors to identify and discover your registered advisors’ online presence. Our multi-query processes and dynamically designed algorithms provide more accurate search results for supervisors to quickly review. With our automated documentation and reporting features, 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 during the online supervision of your registered advisors. SQWatcher will supervise and archive all websites, even those not hosted with your approved providers. It will organize web-page changes into a manageable, easy to use workflow. Automatic triggers based upon your requirements will notify you of pending reviews. These products were developed for the compliance supervisors who are looking for automated solutions to replace manual processes that prove to be ineffective and tedious. Note: NASD Rule 2210 has been superseded by FINRA Rule 2210. Source: https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210  What controls does your firm have in place to aid you in discovering DBAs if your advisors are not disclosing them? “FINRA’s examination, surveillance and risk monitoring programs play a central role in supporting FINRA’s mission of investor protection and market integrity.” “DBAs and Communications With the Public” were one of the findings highlighted. FINRA continues to find that many registered representatives are not compliant with FINRA Rule 3270 in trying to conceal their outside business activities. “FINRA observed that certain firms did not maintain sufficient WSPs and controls, or provide adequate disclosures regarding the use of DBA names.” 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? That is where our Eagle Eye application steps in. Our multi-query processes and dynamically designed algorithms provide more accurate online search results for you to quickly review. Our new “Risk-Based Review Process” provides added system intelligence, enhanced lexicon capabilities, system learning, and detailed evaluation of your search results. Eagle Eye automatically discovers your riskiest advisors and focuses your attention to where it’s needed. FINRA’s exam report also focused on registered representatives’ use of DBA names on their websites, social media accounts, seminars, and more that failed disclose they were working on behalf of a firm. FINRA also found many instances where there was no hyperlink to FINRA’s BrokerCheck. “Some registered representatives’ websites did not contain a “readily apparent reference” and hyperlink to FINRA’s BrokerCheck on the web pages that included the representatives’ professional profiles, as FINRA Rule 2210(d)(8)(A) (Communications with the Public) requires.” With precision our Eagle Eye application can find undisclosed websites, and social media accounts using the DBA names owned by your registered advisors. Enabling you to supervise and make sure that your advisors are following FINRA requirements. Then, our SQWatcher application can help you monitor, review, approve, and document changes made to your registered representatives’ websites. (Learn more about this application) These two applications become force-multipliers in your supervision program.
The annual FINRA Exam Findings Report is helpful for firms in bringing non-compliance issues to the forefront. It is a good time to reflect and examine on your own WSPs and supervisions procedures. With over 15 years of working in the financial industry, SiteQuest Technologies is an industry leader in providing innovative compliance and supervision software applications and website solutions for the financial industry. Contact us today with your DBA supervision concerns. Read the entire FINRA Exam Findings: http://www.finra.org/sites/default/files/2018_exam_findings.pdf Related Article: Are You Finding Everything You Need to Monitor?  One of our clients has been using the application for almost a year and described Eagle Eye as a “godsend.” Why? Since switching to Eagle Eye, this firm has:
With Eagle Eye’s automated searches, easy-to-use workflow and blacklisting technology, this client was able to do their reviews in a fraction of the time it took when doing it by hand. Not only has this time savings come in handy when it came to other projects, but they were also able to expand their supervision levels and are now looking deeper into the web through our application. It’s certainly turned into a “Win-Win-Win” situation that only required a small investment in a tool that now automates a process that used to be completely manual. Contact us today for a quick demo to see how Eagle Eye can not only save you time but also reduce your compliance risks.  |
About James CellaJames 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! Archives
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9/24/2021