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Broker-dealer e-mail systems must keep pace with firm growth, FINRA says

Daniel A. Nathan (Partner at Morrison & Foerster LLP, Washington, District of Columbia, USA)
Kelley A. Howes (Of Counsel at Morrison & Foerster LLP, Denver, Colorado, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 9 September 2013

63

Abstract

Purpose

The purpose of the paper is to explain the implications of a FINRA disciplinary action and recommend ways for broker-dealers to assess their compliance with supervisory and recordkeeping obligations related to electronic communications.

Design/methodology/approach

The paper explains supervisory failures related to e-mail retention leading to a FINRA disciplinary action, discusses lessons learned, and recommends best practices that broker-dealers should consider implementing to ensure their systems are consistent with relevant FINRA rules including compliance audits, remediation of identified issues, training, and disciplinary actions.

Findings

FINRA is clearly signaling that directing firm resources to the building of a business without a similar commitment to compliance will not be tolerated.

Originality/value

The paper provides expert guidance from experienced financial services lawyers.

Keywords

Acknowledgements

© 2013 Morrison & Foerster LLP

Citation

A. Nathan, D. and A. Howes, K. (2013), "Broker-dealer e-mail systems must keep pace with firm growth, FINRA says", Journal of Investment Compliance, Vol. 14 No. 3, pp. 38-40. https://doi.org/10.1108/JOIC-09-2013-0024

Publisher

:

Emerald Group Publishing Limited

Copyright © 2013, Authors

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