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Background & Summary On July 8, 2019, the US Securities and Exchange Commission (SEC) issued a joint statement in conjunction with FINRA’s general counsel addressing various elements of digital currency amid request for clarity on whether broker-dealers can hold digital assets under federal securities laws. The regulator reiterated its growing concerns relative to investor protection […]

On June 5, 2019 the Securities and Exchange Commission (“SEC”) voted to enhance the regulatory framework standard of conduct for broker-dealers (or “firms”) and provide an interpretation of the fiduciary duty for investment advisers by issuing Regulation Best Interest (“Reg BI”). Hearsay recently reached out to Mitch Avnet of Compliance Risk Concepts (“CRC”) to discuss […]

On June 5, 2019 the Securities and Exchange Commission (“SEC”) voted to enhance the regulatory framework standard of conduct for broker-dealers (or “firms”) and provide an interpretation of the fiduciary duty for investment advisers by issuing Regulation Best Interest (“Reg BI”). The SEC is giving firms a transition period until June 30, 2020.  Reg BI […]

Sold with Jim Ryan. In this episode of CRC-TV, we hit the streets of NYC with Jim Ryan, Director of Business Development at Compliance Risk Concepts discuss the art of sales and what he will be bringing to the CRC team. #CRCTV CRC-TV Presents “SOLD” with Jim Ryan Directed by Dillon Avnet and Ethan Conway […]

Mitch Avnet had the privilege of moderating a session on “Compliance Trends in Advisor Communications” at Hearsay Summit this year. The session was well attended by compliance officers from enterprise wealth management and insurance companies whose respective organizations have taken a careful, thoughtful and pragmatic approach to enable advisors to communicate with clients and prospects over multiple channels.

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(The Economist | May 2019) Excerpt from the article Rise of the No Men The past decade has brought a compliance boom in banking. A recent episode of “Billions”, a television drama about Wall Street, captured the rainmakers’ frustration: so fed up is “Dollar” Bill Stern with having his wings clipped by Ari Spyros that […]

Mitch Avnet shared his thoughts on pharmaceutical compliance and the opioid crisis in the following Law360 article titled With Opioid Charges, DOJ Signals Compliance Fixation by Alison Noon. Mitch reasoned, “If a company has reservations about a dual-function compliance officer, it can help to follow the money and decide whether their other compensation could undermine their […]

You are Cordially Invited to FINRA Happy Hour Event At CRC, we like to keep it breezy, so please come join us at this great SpeakEasy! May 16th from 5:00-7:00 p.m. Denson in D.C. 600 F St NW, Washington, DC 20004 www.densondc.com WILL YOU BE JOINING US? Use the form below to RSVP to our […]

CRC is delighted to sponsor the upcoming 2019 FINRA Annual Conference on May 15-17 in Washington, D.C. Please stop by our booth to say hello and check out the newest addition to the Compliance Crusader family! FINRA’s premier event—the Annual Conference provides the opportunity for practitioners, peers and regulators to exchange ideas on today’s most […]

President and Chief Executive Officer of the Investment Adviser Association, Paul Cellupica, has posted a letter to President & Chief Executive Officer of the Investment Adviser Association, Karen Barr, on behalf of the division’s staff, asking investment advisers for public comments and input on the Custody Rule as it applies to the emerging landscape of […]

This is the fifth, and final in our series on Building a Business Case for Compliance Technology for Hearsay Systems. In this article, Mitch Avnet shares his thoughts on the final phase of implementation in your compliance strategy, and the important role a project manager or PM will play in the process. Reaching the implementation stage of your […]

I Want My CRC-TV! Always ahead of the curve, Compliance Risk Concepts explores the endless opportunities of Compliance and Video in a New Season of CRC-TV. Coming soon to screen near you, the All New Season of CRC-TV offers a refreshing look at compliance through a fun and creative lens. Stay tuned and learn how […]

With 2018 behind us and 2019 underway, we find ourselves in a position to look back across the regulatory landscape on what transpired over the course of 2018 in an effort to anticipate what this year may bring for Broker-Dealers.

This is the fourth of our series on Building a Business Case for Compliance Technology for Hearsay Systems. In this article, Mitch Avnet shares the process of building a business case within your firm to support investment in compliance technology, arguing the case that technology vendor due diligence will ensure an efficient and productive future with confidence. Today’s […]

With 2018 in rear-view mirror and 2019 underway, we find ourselves in a position to look back across the regulatory landscape on what transpired over the course of last year in an effort to anticipate what this New Year may bring for Investment Advisers.

Due Diligence Works, Inc. (DDW) sat down with Mitch Avnet, Founder and Managing Director of Compliance Risk Concepts, to discuss the evolution of communication, particularly as it relates to texting and social media, and the growth opportunity it presents for Financial Services firms and their Financial Consultants. They discussed the business potential and how best […]

NEW YORK, NY /PRESS RELEASE/ – Building on its leadership position in the compliance professional services sector, Compliance Risk Concepts LLC (CRC) today announced the hire of James (Jim) K. Ryan as Director of Business Development. At CRC, Jim will continue to drive growth and expansion in CRC’s core business verticals, which include broker-dealer, investment […]

This is the third of our series on Building a Business Case for Compliance Technology for Hearsay Systems. In this article, Mitch Avnet shares the process of building a business case within your firm to support investment in compliance technology. Implementing compliance technology doesn’t have to happen all at once, and it doesn’t have to happen inhouse. Cloud-based […]

On December 7, 2018, FINRA released their annual Exam Findings Report. This is an important tool for Member Firms to leverage when prioritizing their compliance initiatives for 2019. CRC has reviewed this report and summarized key takeaways in FINRA 2018 Exam Findings Report and Regulatory Update Reminder. As always, we understand that industry professionals have […]

This is the second of our series on Building a Business Case for Compliance Technology for Hearsay Systems. In this article, Mitch Avnet shares his solution to one of the most prevalent fundamental challenges firms face today, an over-reliance on manual, bifurcated and disparate processes. This over-reliance limits their ability to get a comprehensive, accurate […]

This is the first of our monthly blogs for Hearsay Systems.  Over the next few months, in conjunction with Hearsay, our goal is to arm the financial services industry with information and examples to help risk and compliance professionals build a successful business case to enable texting capabilities within their respective organizations. Right this moment, […]

Annual Compliance Services Offerings The end of 2018 is approaching quickly. CRC would like to remind you that for brokers and advisers with a December fiscal year-end, annual amendments have filing deadlines 60 to 90 days following December 31st. To facilitate streamlined regulatory reporting and filing, CRC offers a suite of services, as outlined below. […]

A proactive approach is best when it comes to advisor-client texting. Join us to learn why! Join our webinar on November 7th at 1pm EDT when Mitch Avnet of Compliance Risk Concepts (“CRC” ) goes online with Phil Burch of Hearsay Systems to discuss how technology can help compliance and supervision teams proactively mitigate risk […]

Come celebrate Compliance Risk Concepts’6 year anniversary at Gallery Henoch with an evening of food, drinks and art. Featuring New City Paintings, Oil Paintings of NYC & Brooklyn by Award-Winning Artist Kim Cogan. When: November 14th, 5:30pm – 8:30pm Where: Gallery Henoch, 555 West 25th Street, New York, NY WILL YOU BE JOINING US? Use […]

To help navigate the wide array of compliance and risk management issues impacting the financial services sector today, broker-dealer compliance officers came together for a mastermind exchange of ideas and knowledge surrounding monitoring and surveillance challenges they face within the securities industry. Hosted by Abel Noser and Compliance Risk Concepts, The Kitano New York offered […]

It’s a bird. It’s a plane. It’s the Compliance Crusader! Today is the day! Join us for the Compliance Crusader Project, a short journey behind the mask and inside the intrigue surrounding our company mascot, the Compliance Crusader. And be on the lookout for the Compliance Crusader throughout the Big Apple! You never know where […]

Join Abel Noser and Compliance Risk Concepts September 5th for the Monitoring and Surveillance Symposium for Broker-Dealers. This afternoon symposium is intended to be a fully interactive session that brings together Senior Level Compliance and Risk Management Executives to engage in the exchange and sharing of ideas, knowledge and various concepts surrounding monitoring and surveillance […]

Coinbase, who recently acquired broker-dealer Keystone Capital Corp in June 2018, announced the addition of Jeff Horowitz as the Cryptocurrency exchange’s new Chief Compliance Officer. Prior to joining Coinbase, Horowitz served as the Global Head of Compliance at Pershing, and previously held positions managing AML and compliance programs at Citigroup and Goldman Sachs. “As Coinbase […]

Compliance Risk Concepts, LLC, a business-focused team of seasoned compliance professionals providing top tier compliance risk management services, has launched its new website in honor of its 5-year anniversary. Mitch Avnet, Managing Partner and Founder of CRC, says, “The launch of our new website has been a significant undertaking to further ensure our clients and followers have […]

Background and Summary On July 6, 2018, FINRA published Notice 18-20 regarding member firm involvement in digital currency. This notice addressed the fact that the market for digital assets, including cryptocurrencies and virtual coins, has grown significantly in recent months, particularly amongst retail investors. The regulator reiterated its growing concerns specific to investor protection, including […]

Hiring the right talent, maintaining accountability for those you hire, and managing through the complex regulatory landscape has never been more important – and more challenging- for financial institutions. Compliance Risk Concepts (CRC) partnered with Sterling Talent Solutions, a leader in global background screening, to publish the white paper, “Employee, Client and Third Party Due […]

TAMPA, Fla., 06/18/2018 –Independent Financial Partners (IFP) has chosen Compliance Risk Concepts (CRC) to implement its broker-dealer filing. The Tampa-based RIA announced on April 6 its separation from LPL Financial in favor of creating its own broker-dealer (BD). Establishing a BD requires the filing of a New Membership Application (NMA) with the Financial Industry Regulatory […]

Sterling Talent Solutions and Compliance Risk Concepts invite you to join us on Wednesday, June 13th for the Sterling Financial Services Summit: Human Capital and Compliance – Bridging the Gap. This afternoon thought leadership session will include Financial Services Executive from Human Resources, Talent Acquisition and Compliance. Date: Wednesday, June 13, 2018 Time: Time: 12:30 pm […]

The world of research sure has changed over the last few decades. When the author Jeanine Oburchay, CRC Director of Research Advisory Practice, first started in the field in 1987, equity research analysts worked primarily for investment banks and broker-dealers. Landing a gig at a bulge bracket firm meant that as long as you delivered […]

According to the 2018 Exam Priorities Report released in February, OCIE plans to monitor the sale of products in the cryptocurrency and initial coin offering markets and examine for regulatory compliance in instances where products are determined to be securities. It is expected that the SEC, and likely FINRA, are aiming to treat cryptocurrencies as […]

Compliance Risk Concepts presents Fast Facts: Customer Due Diligence, A Quick Guide To FinCEN’s New Requirements. It offers a snack-size snapshot of key points from our more detailed regulatory release Understanding FinCEN’s Customer Due Diligence (CDD) Final Rule, that outlines FinCEN’s new Customer Due Diligence (CDD) Final Rule, in advance of its effective date on […]

Beautiful day in Washington D.C., as Mitch Avnet had an opportunity to connect with former chairperson of SEC, Mary Schapiro. As Chairman of the U.S. Securities and Exchange Commission, Mary L. Schapiro helped strengthen and revitalize the agency; oversaw a more rigorous enforcement program; and, shaped new rules by which Wall Street must play. Chairman […]

Now that 2017 has ended and 2018 is emerging on the regulatory horizon, we find ourselves in a position to look back on what has transpired over the course of the past year in an effort to anticipate what the New Year may bring for Broker-Dealers. In the following Annual Broker-Dealer Regulatory Review and Outlook […]

As we approach the Thanksgiving Holiday, the end of 2017 will be here before we know it! As former Chief Compliance Officers, CRC completely understands year-end pressures for FINRA registered broker-dealers and the need/importance of executing and completing mandatory annual Compliance requirements. Over the last several years, we’ve helped many Broker-Dealers complete each of the […]

Episode 3: Hosts Mitch Avnet discusses the following information specific to Annual Compliance Reviews and CEO Certification process: · Holistic Review of Your Organization · Leveraging External Resources · Manual and Technology Driven Workflows · Ample Time To Review Results · Documenting Testing and Significant Compliance Concerns

During the recent collaboration on: Data Integrity and Governance for FINRA registered broker-dealers: http://goo.gl/lw3v45, Mitch Avnet, Compliance TV host, sat down with Ian Manocha, CEO of Gresham Computing for the following interview. Gresham Computing is dedicated to providing something that is vital to modern business but often difficult to achieve – Real-time Financial Certainty® Whatever […]

In this episode of Compliance-TV Mitch Avnet and Roland Reyes discuss the launch of the new Compliance Hotline mobile app. Financial Service organizations can now receive on-the-go answers from best-in-class industry experts on ongoing and onerous regulatory compliance issues. Available for download on Google Play and iTunes.

Compliance TV In this episode host Mitch Avnet answers the question, what was your goal in establishing Compliance Risk Concepts 4 years ago? As a former Chief Compliance Officer (“CCO”), Mitch had been a “buyer” of professional services for a good portion of his 20 year “in-house” career. The decision to launch CRC ( in […]

With regulatory aggressiveness at historically high levels. Financial institutions must rethink how they thread the compliance needle and reshape the endless regulatory noise into coherent action that promotes dynamic and impactful risk management processes. At Compliance Risk Concepts, we know that your business doesn’t benefit from compliance advice that’s academic or theoretical. Unlike traditional compliance […]

Through our strategic agreement with Phocion Investment Services (Phocion), Compliance Risk Concepts ‎(CRC) is proud to offer GIPS® Verification Services to existing and prospective clients. The intention of GIPS® Verification is to provide existing and prospective clients with additional credibility that the investment firm adheres to industry best performance practices. GIPS® is formulated and maintained […]

As noted in the 2017 Regulatory and Examination Priorities Letter, FINRA will review firms’ supervisory procedures for hiring or retaining statutorily disqualified and recidivist brokers. FINRA will examine firms’ due diligence on these individuals, which will include determining whether, as part of the verification process, a firm or third-party service provider conducts a national search […]

With regulatory aggressiveness at historically high levels. Financial institutions must rethink how they thread the compliance needle and reshape the endless regulatory noise into coherent action that promotes dynamic and impactful risk management processes. At Compliance Risk Concepts, we know that your business doesn’t benefit from compliance advice that’s academic or theoretical. Unlike traditional compliance […]

On October 1, 2017, regulatory changes go into effect for investment advisers. The amended Form ADV will require investment advisers to expand the information they report on Form ADV about separately managed accounts and other important aspects of their advisory business. The SEC also adopted a number of other amendments to the Form ADV and […]

NEW YORK (NEW YORK) | CHICAGO (ILLINOIS) Compliance Risk Concepts (“CRC”), a top-tier compliance consulting services firm, and NexTier Consulting Solutions (“NexTier”), a leading risk management consulting services firm are pleased to announce that they have formalized a strategic partnership to serve the investment management community.   Compliance Risk Concepts and NexTier Consulting Solutions The […]

Discussing Benefits of Strategic Alliance Between Compliance Risk Concepts and Phocion Investment Services Join CRC and Phocion for a more in-depth discussion on how their new partnership will benefit their clients in both the US and Canada. Date: September 12, 2017 Time: 12:00 pm – 1:00 pm EST. REGISTER HERE After registering, you will receive a confirmation […]

NEW YORK (NEW YORK) | MONTREAL (CANADA) Compliance Risk Concepts (“CRC”), a top tier compliance consulting services firm, and Phocion Investment Services (“Phocion”), a leading service provider in performance, due diligence and compliance, are pleased to announce that they have formalized a strategic partnership. The partnership benefits CRC’s clients by expanding their offering to include […]

When I was a freshman at DeSales University my younger, teenaged sister called me one night to tell me, in a very excited tone, “Guess what! There is this thing called the World Wide Web, it’s so cool! You can talk to people from all over the world!”. I know, I’m dating myself but what […]

  If your firm is struggling with the management and analysis of conflicts of interest, learn from a leading industry expert about how to begin to tackle the challenge. Join Protegent, Compliance Risk Concepts, and your peers for an hour-long webinar, sharing experiences and lessons learned in helping firms transform from manual-based conflicts reviews, to […]

As the second quarter of 2017 draws to a close we’ve put graduations behind us and for some of us, we eagerly await the start of summer camp, others plan day trips to the beach (raise your hand if you are going to the Jersey shore), invite friends for the inevitable BBQs that, for some, […]

CRC furnishes sensible regulatory risk management services and support that achieve a comfortable balance between a client’s commercial interests and the critical need to withstand regulatory scrutiny. In line with our ongoing efforts to provide innovative, cost-effective and practical solutions to our clients, we are extremely excited to introduce PaCE. PaCE is a cloud-based compliance […]

BULLETIN: The Department of Labor (DOL) Fiduciary Rule Spotlight On Talent: Scott Brown, Senior Consultant at Compliance Risk Concepts The Department of Labor (DOL) Fiduciary Rule, was originally scheduled to be phased in over the period encompassing April 10, 2017 – January 1, 2018, but is now to be phased in starting June 9, 2017 including a transition period […]

Thank you to all who attended the June 20th webinar, Establishing A Regulatory-Proof Broker/Dealer Compliance Program in which Mitch Avnet, Founder and Managing Partner at Compliance Risk Concepts (“CRC”) and Kristi Kuhn, Senior Solutions Consultant at ProcessUnity discussed the necessary components of establishing and maintaining the necessary infrastructure to support and scale a best-in-class broker-dealer […]

  Mitch Avnet to present at upcoming IAA 2017 webinar series, Risk, Mitigation and Insurance Issues for Investment Advisers. Investment advisers face constant challenges to stay current and comply with new and changing regulations in an evolving market place. This webinar will help advisers to better understand these regulations and how they may reduce or […]

Assessing Market-Wide Risks Spotlight On Talent: Portia Amato, Compliance Officer  This is the third installment of our 3-part series, It’s 2017, What Are The SEC’s Priorities?, in which we discuss the 2017 examination priorities of the Office of Compliance Inspections and Examinations of the Securities and Exchange Commission. This year the SEC priorities are organized […]

Looking for an easy way to lower the operating costs of your Research Department? Consider outsourcing your Supervisory Analyst function. Chances are, you can save quite a bit. And with CRC, you won’t sacrifice an ounce of speed or quality. Full-time SAs often encounter significant periods of downtime. That downtime, of course, is downright expensive. […]

Risks Specific To Senior Investors and Retirement Investments Spotlight On Talent: Portia Amato, Compliance Officer  Now that we have examined the SECs’ focus on Retail Investors (Part 1: It’s 2017, What Are the SEC’s Priorities?), it is time to turn our attention to the OCIE’s 2nd focus area: Risks specific to Senior Investors and Retirement […]

Examining matters of importance to retail investors Spotlight On Talent: Portia Amato, Compliance Officer  By now, every CCO and their team have asked themselves this question, and if you have not already, this is the time to do so, especially if you have not been the lucky host to a SEC Audit in some time. […]

Sometimes, Being Two-Faced is a Good Thing… Spotlight On Talent: David Amster, Principal and Head of Fund and Dealer Advisory On January 1, 153 B.C., Rome was the site of the first recorded new year’s celebration during which Romans paid tribute to Janus – January’s namesake and the Roman god of beginnings and endings. Janus […]

Spotlight On Talent: Dan Dorsky, Principal and Head of Anti-Corruption and Ethics These are fascinating times for U.S. and global enforcement of anti-bribery laws. More resources are being dedicated, more countries are participating, and the resulting outcomes have been extraordinary fines and penalties, along with enhanced risk of individual criminal prosecutions. Concurrently, the recent U.S. […]

COMPLIANCE BULLETIN: OUT WITH THE OLD…IN WITH THE NEW Spotlight On Talent: Lilian Colpas, Senior Compliance Consultant Why is January 1 different from all other days of the year? After all, nothing fundamentally really changes. Nevertheless, most of us see January 1 as a new beginning in which we resolve to renew ourselves and discard […]

Join the Hewlett Packard Enterprise solution team and Compliance Risk Concepts (CRC) at the HPE Information Governance Financial Regulatory Compliance Roundtable. Date: Wednesday, January 25, 2017 Time: 12:00 pm – 3:30 pm ET (full lunch served with happy hour after) Location: The Lambs Club, 132 W. 44th St., NY NY 10036   This informal meeting will look at […]

COMPLIANCE BULLETIN: SEC WHISTLEBLOWER REGULATIONS Spotlight On Talent: Lilian Colpas, Senior Compliance Consultant The most recent SEC announcement by OCIE correlates to the point that whistleblowers have an incentive to earn millions of dollars from your ineffective compliance program. The SEC has monetary incentives to draw out these employees and expose the trials and tribulations […]

With the end of 2016 just days away, 2017 will be here before you know it! As former Chief Compliance Officers, CRC completely understands year-end pressures for FINRA registered broker-dealers and the need / importance of executing and completing mandatory annual Compliance requirements. Over the last several years, we’ve assisted many Broker-Dealers in completing each […]

  It is with great enthusiasm that Compliance Risk Concepts (CRC) is proud to announce that we are moving our NYC headquarters. The continued loyalty from our clients has fueled our remarkable growth, making a new location the next exciting step. On November 15th, CRC will occupy the 11th Floor of 441 Lexington Avenue. Our […]

by Dan Dorsky, Principal, Anti-Corruption and Ethics Practice. An enforcement action jarring the financial services sector has been resolved. Och-Ziff Capital Management Group LLC agreed to pay a combined penalty of $412 million towards its settlement with the Department of Justice (“DOJ”) and Securities & Exchange Commission (“SEC”) related to the agencies’ Foreign Corrupt Practices […]

NEW YORK, Oct. 25, 2016 /PRNewswire/ — Expanding its scope of compliance specialties to Anti-Corruption and Foreign Corrupt Practices Act resolution, Compliance Risk Concepts LLC (CRC) today announced the hire of Daniel Dorsky as Principal of its Anti-Corruption and Ethics Practice. “CRC is excited to expand its services to advise clients on best practices and […]

COMPLIANCE BULLETIN: DOL FIDUCIARY RULE Spotlight On Talent: David Amster, Principal and Head of Fund and Dealer Advisory The United States Department of Labor (“DOL”) recently finalized rules that require financial institutions that offer retirement advice to address conflicts of interest (“COIs”) that arise as a result of offering such advice (the “Fiduciary Rule”). The […]

  Building on its team of compliance advisory professionals, Compliance Risk Concepts, LLC (CRC) has hired of David J. Amster as Principal and Head of its Fund and Dealer Advisory practice. “David’s professionalism and breadth of buy-side and sell-side product knowledge gives him 360-degree awareness of the issues financial services firms confront daily in the […]

Several times over the past decade FINRA has indicated they may be considering making it a requirement for broker-dealers to maintain errors and omission insurance (E&O) to cover the payment of arbitration awards to investors. A 2013 article in the Wall Street Journal indicated that FINRA was “frustrated” over nonpayment of arbitration awards to investors […]

Whether you are a small-town doctor or a powerful hedge fund manager – the SEC doesn’t discriminate! If you are abusing your fiduciary duty and use material, non-public information to trade securities – you will be caught and you will be charged with insider trading. Combat insider trading within your firm by learning the right […]

It’s hard to believe that almost four (4) years ago, my partners and I developed the strategy and business plan that would ultimately lead to the launch of Compliance Risk Concepts (“CRC”), a compliance professional services organization, headquartered in New York City. In the spirit of candor and full transparency, I didn’t wake up one […]

Compliance Risk Concepts is honored to be recognized by Enterprise Services Outlook (ES Outlook) as one of the top 25 Most Recommended Compliance Services Providers of 2016. “Given that the market is swarming with compliance service providers, picking a particular agency is often a daunting exercise. …the editorial team at ES Outlook has critically evaluated […]

NEW YORK, NY– Compliance Risk Concepts (“CRC”) launches new mobile app for financial service organizations. The CRC Hotline app offers on-the-go answers from industry experts regarding ongoing and onerous regulatory compliance issues. It connects Compliance Officers, CEOs of independent broker-dealers, Managing Partners of independent investment advisers, Chief Financial Officers (“CFOs”), Chief Operating Officers (“COOs”), Chief Risk […]

Join Gresham and Compliance Risk Concepts (CRC) for a Data Integrity and Governance for Broker-Dealers and Investment Advisers roundtable discussion and hear first-hand, from two former Senior Executives at FINRA, Bill Hayden and Jeff Holik. Date: Tuesday, June 14, 2016 Time: Time: 12:00 pm – 5:00 pm ET Lunch 12:00pm – 12:45pm Roundtable discussion 1:00pm […]

Compliance Breakfast Forum: Conflicts of Interest Join Compliance Science (CSI) and Compliance Risk Concepts (CRC) as we present a Conflicts of Interest roundtable discussion. Date: Thursday, May 19, 2016 Time: Time: 8:30 am – 11:00 am ET Location: Pillsbury Winthrop Shaw Pittman LLP, New York, NY The success of any end-to-end Conflicts Management Program is predicated […]

Today, there is a new paradigm of regulatory expectations, creating increasingly daunting compliance and operational risk management challenges on FINRA registered broker-dealers. Many of these challenges are related to the governance and control environments, specific to the data that is so heavily relied upon to ensure broker-dealers continue to meet the ever expanding list of […]

  Thomson Reuters Annual Financial and Risk Summit in New York Date: May 4, 2016 Time: Time: 8:00 am – 5:30 pm ET Location: Marriott Marquis, New York Click Here To Register Mitch Avnet is thrilled to be participating in the upcoming Thomson Reuters Annual Financial and Risk Summit in New York City in the […]

CRC Announces Forthcoming Whitepaper Addressing Data Quality and Data Integrity Issues Impacting Broker-Dealers CRC is pleased to announce a forthcoming whitepaper written in conjunction with Gresham Computing plc addressing data quality and data integrity issues impacting FINRA Registered broker-dealers. As we’ve all recently learned in FINRA’s Regulatory and Examinations Priorities Letter for 2016, FINRA is […]

Navigating Your Next SEC Exam Experienced and skilled compliance officers are adept at managing almost any regulatory exams. These compliance officers use their instincts, training, and experience to manage through the issues that arise during an exam. As a compliance consultant for the last two years, I have seen the inner-workings of multiple firms and […]

Compliance Science, Inc. is hosting a February webinar entitled, “Navigating Your Next SEC Exam“. The webinar conversation will focus on a range of considerations that represent the end-to-end lifecycle of an exam. This 60 minute webinar will be moderated by Charles Steerman, VP Product Solutions, Compliance Science with guest panelists Mitch Avnet, Founder and Managing […]

FSO Knowledge Xchange is hosting its exclusive Governance, Risk Management, and Compliance Breakfast Briefing on February 25th, 2016 at the University Club in New York City. During this half day forum, industry experts from leading financial firms, will share innovative ideas, emerging trends, and best practices for adhering to enterprise-wide GRC requirements, and making them an integral […]

Building a Compliance Professional Services Organization   Are we Hipster Chic? This past weekend I frequented a hipster coffee shop in Greenwich Village.   As I drank my “chichi” cup of coffee, I couldn’t help but overhear the conversation at the table next to me.  It was two young gentlemen discussing how the nuances and imperfections […]

The SEC alleges that an employee, who worked as an associate in Goldman’s compliance department, traded on confidential information contained in e-mails sent and received by Goldman investment bankers. The employee gained access to investment banker e-mails as part of his work developing surveillance software designed to monitor other employees for potential misconduct such as […]

The OCIE staff of the SEC released a Risk Alert relating to the Outsourcing of Chief Compliance Officers and Compliance Activities. Truly, the findings and risks shouldn’t be a surprise to anyone. My colleagues and I have all recently left “in-house” Compliance positions to become “outsourced compliance advisors.” As Consultants that have recently had the […]

  Date: Nov 16-17, 2015  Sponsored by: Compliance Science This year’s conference is shaping up to be another great one. The list of speakers include Mitch Avnet and Compliance Science partners from leading security, consulting, and law firms as well as other seasoned compliance professionals who will discuss best practices for compliance automation and SEC exam preparation. […]

ENTER IF YOU DARE!   As Halloween is quickly creeping toward us – 2015 will vanish right before our very eyes! As former Chief Compliance Officers, CRC understands how frightening, scary and daunting it can be for Broker-Dealers to prepare for / and execute their year-end Compliance requirements. Over the last few years, we’ve helped […]

Goldman Sachs Group, Inc. will report earnings on 10/15/2015 before the market opens. Last week Goldman publicized that it would announce its earnings via Twitter (@Twitter). The talk since the publication has been about the use of social media and Twitter becoming a viable and safe competitor in the field of company news distributors. That […]

9 of 24 BDs Reviewed NOT PREPARED to Respond to Customer Withdrawal of Funds Recently FINRA published its findings regarding a funding and liquidity review of 43 broker/dealers.  Has anyone noticed that 9 out of 24 BD’s Reviewed are not prepared to respond to customer withdrawal of funds.  In fact, the only test that all […]

The State of New York recently passed legislation requiring those transacting in virtual currency to become licensed. The new rules mirror much of what is already in place for many broker-dealers, banks, and other financial institutions. However, there are some important parts of the legislation that may change written policies or require new policies be […]

  Emmanuel Olaoye, Thomson Reuters As the Financial Industry Regulatory Authority embraces the cloud and expands its monitoring technology for the big data era, firms may feel pressure to increase their own capacity to provide data. As the Financial Industry Regulatory Authority expands its monitoring technology for the big-data era, firms may feel pressure to […]

What Help Do Compliance Clients Need? By Lori Tripoli Law Practice Management Expert Even as the regulatory environment burgeons and touches on seemingly every aspect of everyday life as well as on one’s workaday world, it can be easy to forget how flummoxed the regulated community might be by even a slight change in a […]

  C-CON Cleveland – Compliance Officer Network Location: McDonald Hopkins LLC, 600 Superior Ave, Cleveland, Oh 44114 Date: Tuesday August 4, 2015 Time: 3:30 pm CPE Credit: 1 Credit Program Agenda: 3:15 – 3:30 p.m. Registration 3:30 p.m. Molly Brown on Cybersecurity 4:00 p.m. Mitch Avnet on Managing Conflicts & Trends in Compliance Technology 4:45 […]

Beautiful day in Washington D.C., as Mitch Avnet had an opportunity to connect with former chairperson of SEC, Mary Schapiro.   As Chairman of the U.S. Securities and Exchange Commission, Mary L. Schapiro helped strengthen and revitalize the agency; oversaw a more rigorous enforcement program; and, shaped new rules by which Wall Street must play. […]

This article originally published by The Global Association of Risk Professionals (GARP) Massachusetts Mutual Life Insurance Co. has assigned executive vice president and chief enterprise risk officer Elizabeth (Betsy) Ward the additional role of chief actuary. The move is seen as part of a trend to streamline and clarify risk governance amid growing marketplace complexity. […]

In a non-exclusive co-branding agreement, Compliance Risk Concepts and FinWebTech have teamed up to provide broker-dealers, registered investment advisors, banks and other financial institutions, an automated cost effective solution to improving operations, reducing risk and maintaining a strong culture of compliance. Cost Effective Compliance Solution For The Financial Industry Developed with input from ex-regulators from […]

As a Former Chief Compliance Officer, I am frequently asked by my clients to help them find /understand where the “risk” is in their compliance programs / throughout their organizations. For me, a huge part of an organization’s risk profile comes down to the quality of their surveillance protocols and the quality of information gleaned […]

  RegEd 2015 Compliance Alliance Client Conference Date: May 4-6, 2015 Location: Raleigh Marriott City Center | Raleigh, NC Join financial services CCOs, Compliance Professionals, senior representatives, regulators and former regulators and gain a new understanding of expanding and new compliance obligations. Learn how other firms are working through their challenges and learn best practices […]

Washington D.C., April 20, 2015 — The Securities and Exchange Commission today charged BlackRock Advisors LLC with breaching its fiduciary duty by failing to disclose a conflict of interest created by the outside business activity of a top-performing portfolio manager. BlackRock agreed to settle the charges and pay a $12 million penalty. The firm also […]

The world has changed in cyber space. It used to be a company could create a strong exterior wall with firewalls, intrusion detection, virtual private networks and a robust set of virus response tools to keep the “bad guys” out of the critical data you use to perform your business dealings. That was Then and […]

Amid a tough climate of regulatory enforcement and an explosion of new rules after the financial crisis, many large companies—especially financial institutions—have beefed up their staffing on risk and compliance. Citigroup, for example, now boasts nearly 30,000 employees dedicated to regulatory and compliance issues. As 2014 drew to a close, HSBC was well on its […]

The Differences Between Broker-Dealers and Investment Advisers Over the past few years, we have discovered that many of our clients and prospects have taken a genuine interest and are often seeking information, trying to ascertain the benefits / issues that exist within the Broker-Dealer and Investment Adviser models. This includes, but is not limited to, […]

As we all contemplate our priorities for 2015, we can be rest assured that Cybersecurity will continue to be a focus area for FINRA, the SEC and other regulators in the coming year. Based on our understanding and utilization of the NIST CICS framework, we can offer your organization a best-in-class, cost effective assessment, training, and technological suite of solutions that can be tailored to meet your company’s specific needs, requirements and budgetary constraints.

In the wake of the many highly publicized data-breaches in 2014, our clients have reached out to us for advice and guidance in an effort to increase the overall awareness of Cybersecurity risk within their respective organizations. 

The Securities and Exchange Commission (“SEC”) recently announced an enforcement action against two broker-dealers that apparently failed in their “gatekeeper roles” and improperly engaged in unregistered sales of microcap stocks on behalf of their customers. This action, along with issuance of the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) National Exam Program Risk Alert […]

YOU BETTER CHECK YOURSELF – BEFORE YOU WRECK YOURSELF End of Year Compliance Requirements For Broker Dealers As the end of 2014 quickly approaches, this Compliance Bulletin serves as a notice and reminder to Broker-Dealers regarding year-end responsibilities that must be executed in accordance with FINRA / SEC regulatory requirements. Reconciling your current “state of […]

Over the past several years, the massive and sweeping changes in the regulatory environment have forced financial services organizations to focus their attention and efforts toward ensuring their internal controls adequately capture all applicable laws & regulations. So many firms are still struggling with the methodology and infrastructure required to effectively execute on these demands. […]

SAVE THE DATE : October 22, 2014 Think Tank 2.0 Meet with your peers to discuss challenges and practical solutions around the Dodd Frank Trade Reconstruction Regulation.

Join SmartBrief Risk and Compliance Editor Sean McMahon and panel Harald Collet, Stephen Marsh and Mitch Avnet, as they discuss trade reconstruction challenges in a webinar sponsored by Bloomberg Vault Tuesday September 16 1:00pm-2:00pm EDT

Mitch Avnet notes that firms lacking “consistent and cohesive training and messaging to mid-level managers” place their organizations at great risk. “An organization must create an awareness and culture encouraging employees to raise their hands…

Bloomberg Vault Webinar: Trade Reconstruction for Compliance Officers Thursday August 21 1:00pm-2:00pm EDT Presented By: Harald Collet Global Head of Bloomberg Vault and Moderated By: Mitch Avnet Managing Partner, Compliance Risk Concepts

Not since the Great Depression has such a comprehensive financial regulatory reform measure been taken as the Dodd-Frank Wall Street Reform and Consumer Protection Act, or “Dodd-Frank Act”. Under these new rules, one of the most significant challenges for Compliance Officers is the work set surrounding the CFTC’s trade reconstruction requirement. Trade reconstruction imposes a […]

NEW YORK, NY, July 7, 2014 – Compliance Risk-Concepts (“CRC”) announced today that John Anderson has been named as Vice President of Business Development. Former VP of Corporate Bond Trading/Sales at Wells Fargo, John’s diversity of experience has enabled him to gain deep transactional knowledge of various equity, fixed income and derivative products, as well […]

The strategic partnership between Four Points and Compliance Risk Concepts serves as a success model for Independent Broker-Dealers and Investment Advisers challenged by the current regulatory and economic environment.

Mitch Avnet confirmed as speaker for Thomson Reuter’s Compliance and Risk Summit at the Marriott Marquis Hotel in New York City.

Recent SEC enforcement actions have increased focus on how well advisers and boards of registered and unregistered investment companies provide compliance oversight. Download the Investment Adviser Bulletin and stay up to date with the regulatory landscape. This month Valerie Lewis examines four examples that touch on best execution practices and disclosures, valuation of securities, and oversight of sub-advisers.

SAVE THE DATE : June 5th, 2014 Meet with your peers to discuss challenges and practical solutions around the Dodd Frank Trade Reconstruction Regulation.

Public companies should determine the best way to embrace and utilize social media –The Social Media Governance for Public Companies Bulletin provides recommendations for guidance and ongoing training in regard to your company’s Next Generation Social Media Policy.

When you click “Submit & View Compliance TV” you will be granted access to the premiere episode of CRC’s “outreach” web series, “Compliance TV”, filmed live in the studios of the Money Business Life Network (“MBLN”) in San Diego, CA.,

Mitch Avnet had the honor of moderating this year’s RCA panel on recent FINRA and SEC exam trends. This is RegEd’s 3rd year of hosting the spectacular event, that brings over 100 compliance professionals, industry experts, regulators and industry consultants together under one roof.

In keeping with our overall objective, we are pleased to announce the launch of CRC’s new electronic brochure. This interactive overview provides a consolidated view of client testimonials, our services and solutions and the verticals we currently support.

In light of the critical role information technology (IT) plays in the securities industry, the increasing threat to firms’ IT systems from a variety of sources, and the potential harm to investors, firms, and the financial system as a whole that these threats pose FINRA is now conducting an assessment of firms’ approaches to managing cyber-security threats.The four broad goals that you need to know about FINRA’s Cyber Security assessment…

The SEC’s Compliance Program Initiative and 2014 Examination Priorities should serve as a “wake up call”.

On January 9th, the SEC published it’s National Examination Priorities for 2014. On the top of their list – Fraud Detection and Prevention, Corporate Governance, Conflicts of Interest, Enterprise Risk Management, Technology and issues specific to Dual Registrants.

The monthly Compliance Bulletin Service provides the information your organization needs- at the speed it can handle it. Let the trusted Compliance professionals at CRC do the hunting, gathering and data-mining for you. Take a peak by downloading a complimentary Compliance Bulletin.

It’s Time For Your 15 Minutes… As a CRC insider, for a limited time we are offering a 15 minute call to discuss a complimentary review of one of the following…

On 10/30/2013, CRC conducted its first industry Compliance Roundtable. Hosted by Barry Barbash, Partner at Willkie, Farr and Gallagher LLP, there were over 30 people in attendance. Panelists and guests included Chief Compliance Officers and Senior Compliance Officers from TD Securities, PNC Capital Markets, Santander, Wells Fargo, Deutsche Bank and Key Capital Markets. In addition […]

The recent action taken by the SEC against three Investment Advisers should serve as a “wake up call” for the IA sector. IAs should utilize the recent sanctions as a “road map” / “checklist” for their own internal controls.

Compliance in Financial Services White Paper | Compliance organizations have had good success leveraging new technologies to improve efficiency, but recent trends as discussed will increasingly force compliance leaders to take action to mitigate the risks arising from the data and regulation explosion.

Round table discussion of senior compliance risk management executives from leading financial services institutions on October 30, 2013. Expected attendees include other senior compliance risk management executives.

Four Points Capital Partners Llc Announces Partnership With CRC, to create and shape its Compliance Culture in the early stages of its evolution.

CRC Service Spotlight: 3012 / 3130 Testing and Certification Annually, FINRA member broker-dealers are required to test and verify the adequacy of their supervisory program, and the CEO is required to certify their awareness of the program’s state. But can your firm’s principal sign with confidence? Regulators require a report for testing and verifying supervisory […]

Look behind the scenes at how Mitch Avnet and his team are developing business cases to substantiate investments in Compliance technology.

As members of the Financial Services Industry, we find ourselves in the position of having an inordinate amount of confidential information at our disposal…

Summary:  Dodd-Frank Trade Reconstruction Expert Panel INTRODUCTION On June 5th, 2014, Bloomberg Vault and Compliance Risk Concepts (“CRC”) hosted a special roundtable at Bloomberg’s New York headquarters specific to the Commodity Futures Trade Commission’s (“CFTC”) Trade Reconstruction Requirements for swap entities.   The event was attended by senior compliance executives and financial services firms representing nearly […]

Compliance, Operational and Financial Risk teams face complex challenges in creating appropriate “control” environments. Many factors impact and influence our ability to provide valuable oversight and insight to the discrete risks we face daily. These include: ✓ Increasing transactional volumes ✓ Required transactional data existing on numerous platforms and systems ✓ Inconsistent data formats ✓ […]

One of the primary drivers for Compliance Risk Concepts (CRC) is to raise the awareness level and thought process related to real world compliance and risk issues in a “down to earth,” realistic and relatable way. Our goal is to help our clients, prospects and readers decipher the challenges faced by compliance and risk professionals […]

CRC partners with Thomson Reuters, the world’s leading source of intelligent information. This is one of CRC’s many successful, strategic partnerships. To learn more, visit our Partners page.

When I first heard the term “Big Data” a few years ago, I immediately thought it was some industry “jargon” and didn’t pay much attention to it. In fact, the more I heard the subject of Big Data being raised, I would equate it to a comedic sketch conjured up on a Seinfeld episode – […]

Beware of “Snake Oil Salesmen” As is the case with any growing industry sector, the opportunity to provide support and services to organizations in need will draw new entrants to the market. A significant number of technology service providers have emerged in the EGRC space. Determining the best fit for your organization can be a […]

Corporate Governance and Enterprise Risk Management are high on the list. Read More.

The ability for Compliance Departments to effectively monitor, measure program effectiveness and provide impactful analysis / reporting is more critical than ever. Being tasked with these requirements has proven to be an extremely burdensome undertaking for most organizations. This is due to the fact that the information needed to provide metrics often exists across multiple […]

Given the depth and breadth of regulatory change in our industry, organizations are challenged more than ever in terms of how to process, manage and execute on applicable requirements. This need has created an opportunity for technology providers to develop “workflow” tools that enable the identification, dissemination and impact analysis of changes in the regulatory […]

I invite you to download our FREE Compliance in Financial Services white paper: HAVE YOUR CAKE AND EAT IT TOO: Improve Efficiency and Turbocharge Your Threat Discovery.