Once implemented, the Compliance Officer used Eagle Eye to do his supervisory reviews of the web by examining the top 25 results listed for each monitored individual. While he found familiar results from his manual processes, he was able to use Eagle Eye’s workflow process to categorize the results, archive them to each user’s Audit Report within the system. He was also presented with new results that he had previously missed with his manual process. These results were extremely important as he found several unreported outside business activities and compliance risks that needed to be addressed and documented for the registered representative being monitored by Eagle Eye.
- • FINRA Rule 3270: Outside Business Activities of Registered Persons
- • NASD Rule 3040: Private Securities Transactions of an Associated Person
- • NASD Rule 3010: Supervision
- • SEC Rule 206(4)-1: Advertisements by investment advisers
- • SEC Rule 206(4)-5: Political contributions by certain investment advisers (“Pay to Play” rule)
- • SEC Rule 206(4)-7: Compliance Procedures and Practices
- 1. Time: Every repeated result that’s reviewed from month-to-month quickly becomes a poor use of his time as he continues to find results with which he is familiar.
- 2. Risk: Because of the large number of repeat results from month-to-month, the Compliance Officer realizes that repeat results are getting in the way of him finding other results that may present a compliance risk to his firm.
In the end, not only has Eagle Eye saved the Compliance Officer a ton of time, but it’s helped him eliminate compliance risks to his firm while clearly demonstrating to his regulatory examiners that his firm is meeting their supervisory requirements.