BLOG
Learn more about what we do and stay up-to-date with industry regulations and trends
We continue to review the monthly disciplinary actions that are reported by FINRA and we are regularly finding rulings and fines that could have been prevented through the use of our Eagle Eye platform. In November 2016, a firm was fined $5,000 from FINRA after it was found that the firm failed to conduct a review of preexisting activities of outside business activities associated with the registered representatives. The findings also included that the firm was unable to provide a supervisory controls report for the years 2008, 2009, 2010 and 2011. Read the full report here. As you know, disclosures are not enough when it comes to Outside Business Activities which is why additional supervision is requested. Trying to discover any outside business activities with just a basic search engine can be very time consuming. Sifting through all of the pages of irrelevant results makes it even harder to find applicable information. Our multi-query processes and dynamically designed algorithms provide more accurate results for review. A compliance professional from a broker dealer in the Midwest said that, "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." Additionally, our clients say that the automated reporting features that Eagle Eye provides dramatically reduces their workload as well. Our compliance designed reports 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. You will have everything you need to respond to a regulator with just a click, and the ability to export it as needed.
Contact us today for a demo to see for yourself how this product can assist you. 1/3/2017
LOOK WHAT WE ACCOMPLISHED IN 2016We are excited to be starting a new year here at SiteQuest Technologies, as well as celebrating Eagle Eye's third anniversary! In those 3 short years, it's been very busy supervising content on the web for our clients. We've increased its scanning power and we continue to improve the intelligence behind what it does. We look forward to tremendous growth in 2017 as we expect to double what Eagle Eye has done up till this point by year's end.
Contact us today to see how we can help your organization take advantage of what Eagle Eye has to offer. Download our infographic here. 12/5/2016
MORE FINRA DISCIPLINARY ACTIONSWe are continually reviewing the monthly disciplinary actions that are reported by FINRA. Almost monthly, we are finding rulings and fines that could have been prevented through the use of our Eagle Eye program. Eagle Eye has been around for several years helping financial firms with their general supervision of the web. One of our clients said, “That one of our previous hurdles was demonstrating to our regulators with documentation that we were conducting the appropriate monitoring. With Eagle Eye's audits reports, that are available directly from the system, we are able to document and show individual findings in an organized manner." In July of this year a brokerage firm received a $5,000 fine from FINRA (Full case details). It was discovered that the firm’s CEO/CCO never conducted its quarterly review of the registered representative’s outside business activity or evaluated any potential conflicts that may have arisen since the initial disclosure of its outside business activity, both of which were required by the firm’s written supervisory procedures. The firm did not have any knowledge of the outside business activates of their representatives As a supervisor, how are you reviewing your representative’s outside business activities? FINRA has provided this helpful form to help you gather this information directly from your employees, but what if your employees neglect to tell you about these OBAs? How do you find out about these activities on your own? That is where Eagle Eye can be part of the solution.
See for yourself how this program can work for you. 10/10/2016
FINES THAT COULD HAVE BEEN PREVENTEDEagle Eye has been around for several years now helping our clients with their general supervision of the web. One of our clients said, “as soon as we implemented Eagle Eye, the system found links that were previously missed with our 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. With Eagle Eye's audits reports, that are available directly from the system, we are able to document and show individual findings in an organized manner." We took a look at some recent FINRA disciplinary actions and discovered several cases in which fines may have been avoided through the use of Eagle Eye. In June of this year an investment company was fined $200,000. This company failed to conduct and report on their due diligence of its registered representatives outside business activities (full case details). The findings also stated that the firm did not have an adequate supervisory system for the review of performance reports used by its registered persons in connection with outside brokerage services. The firm’s written procedures concerning performance reports did not include any provision for the supervisory review of the contents of these reports. The firm did not conduct any supervisory review of the performance reports used by its registered persons. How do you prove your due diligence? Is your documentation in order? Read our September blog post for suggestions that are beneficial in establishing and making sure that an effective record keeping and documentation system is in order. Through Eagle Eye’s automated reporting features with just a click, supervisors will have everything they need when supervising their employees’ web presence including when a result was found, who reviewed it, comments that were made and timestamps on every action taken on the account. These reports give the full picture of your general reviews so that you can respond to a regulator. In April of this year another firm was fined $150,000 for not monitoring their registered representatives’ use of social media sites. Additionally, this firm did not have a mechanism for determining whether its representatives were using social media for securities-business purposes (full case details). The findings also included that the firm failed to conduct required internal inspections, and the majority of the reports from the inspections that did occur as scheduled were inadequate. FINRA also found that the firm did not have any supervisory systems or procedures, written or otherwise, regarding its representatives. Eagle Eye’s relevant results searches will help you identify if your representatives are using social media. Additionally, our search results will help you find blogs, and websites applicable to your associates. Eagle Eye is designed with built-in intelligence that sifts through the web’s clutter and brings the most relevant results to your attention while conducting your reviews.
Our Eagle Eye product is a fraction of the cost of these fines. Many compliance professionals we talk to say Eagle Eye must be seen in action to fully appreciate how much time and energy it can save, how much it improves the quality of their search results, and how much it simplifies documentation. Eagle Eye automatically searches, documents, and reports on your web supervision responsibilities so you have everything you need to find and address issues before they are brought to your attention by a regulator. Want to know more about how our Eagle Eye program can work for you? Contact us today for a demo. 9/19/2016
PART TWO OF NATIONAL PREPAREDNESS MONTHContinually 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. |
About James CellaJames Cella is the President of a growing and innovative compliance technology provider called SiteQuest Technologies. 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 Utah Football and have attended nearly every home game since 2002. Go Utes! Archives
July 2019
Categories |
Products |
Company |
|
1/10/2017