NSCP Member Bulletin

NSCP Regulatory Recaps

Find out what was discussed when NSCP met with SEC Chairman Jay Clayton and Commissioner Hester Peirce last month.

On May 21, 2018 representatives of NSCP had the opportunity to conduct a follow up meeting with SEC Chairman Jay Clayton and an introductory meeting with Commissioner Hester Peirce.

Key conversation points with Chairman Clayton included:

  • Cost of Compliance
  • Regulator Best Interest
  • Investment Adviser Expectations
  • Small Business Audit Correction Act of 2018

Key conversation points with Commissioner Peirce included:

  • CCO Liability
  • “Regulation by Enforcement”
  • Interactions with OCIE

Complete summaries of each meeting are available for all members.



NSCP Currents: Podcast Episode Alert

This month’s feature Podcast is Eversheds Sutherland’s “Connecting the dots: The SEC’s proposed rules on the standard of conduct for investment professionals – a quick guide to what you need to know.“

What just happened? – find out here.

You can listen and subscribe at the following podcast networks. We look forward to your comments and reviews!


NSCP Webinars: 5/9 – The SEC’s Proposed Standard of Conduct Rules and Forms for Broker-Dealers and Investment Advisers

Don’t miss this Webinar on Wednesday, May 9 at 2:30 pm EST


On May 9th, NSCP invites you to join us for a webinar as attorneys from Eversheds Sutherland analyze the US Securities and Exchange Commission’s recently proposed changes to the investment advice standards, disclosures and interpretations for broker-dealers and investment advisers. These proposals would:

  • Require registered investment advisers and registered broker-dealers to provide a brief relationship summary to retail investors
  • Establish a standard of conduct for broker-dealers when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer
  • Provide an interpretation regarding the fiduciary obligations of investment advisers

This presentation will help you analyze the proposed rules, forms and standards of conduct, and the practical considerations that arise from the proposal, including:

  • What changes will broker-dealers need to make when recommending securities as a result of Regulation Best Interest
  • What operational challenges will firms face with the disclosures required under the customer or client relationship summary (Form CRS)
  • What will investment advisers need to do to differently to satisfy the SEC’s interpretation of the fiduciary obligations arising under the Advisers Act



Registration for the NSCP National Conference has Opened

Registration for the NSCP National Conference has Opened

You and 199 of your closest friends can register right now to take advantage of our Spring Sale Pricing!

The 30th Annual NSCP National Conference is here, and we can’t wait for you to join us in Atlanta!

Come discover why over 800 compliance professionals gather each year for three days of industry leading educational and networking opportunities.

You can expect:

  • A robust line-up of keynotes and session topics for every industry focus and experience level
  • Insights on actual practical applications for everyday compliance issues
  • A full day of technology-focused compliance sessions
  • A dynamic mix of session formats – from traditional panels to labs, forums and attendee talk groups

Whether this is your first time joining us, or you’re returning as an old friend, we look forward to having you take part in the only event that is “For Compliance, By Compliance”.

Spring Sale Pricing is valid for our first 200 Registrants or through June 30, 2018 (whichever arrives sooner). Don’t miss your chance to secure your seat and take advantage of our lowest pricing!


JH Award Nominations due 6/1

JH Award Nominations are due by June 1, 2018

The 2018 recipient will be announced and honored at the NSCP National Conference

Do you know someone who:

  • displays a strong commitment to excellence;
  • consistently strives to enhance the compliance profession through their involvement and participation with NSCP;
  • displays a positive attitude and has a commendable can-do approach;
  • and distinguishes herself/himself as a key figure in the compliance community?

Consider nominating them for the NSCP JH Award!


NSCP Currents: Podcast Episode Alert

Listen to our latest episode,“Senior Exploitation from the Trenches.”

The article was written by Z. Jane Riley, Chief Compliance Officer of The Leaders Group/TLG Advisors, Inc. and Carolyn Kasky, Managing Member of Compliance Support Services, LLC.

“As compliance professionals, we often have to wear many hats, from regulatory expert to personnel adviser and everything in between. Senior advocate has joined the roles we have to fill, and it is challenging to know how to respond to the issues raised. Unfortunately, there isn’t an all-inclusive handbook explaining how to respond to concerns about diminished capacity or vulnerable adult exploitation.

A few weeks ago, though, I wished I had such a handbook! I received a call we all dread, an adviser telling me he was uncomfortable with what his client was asking him to do…



NSCP Member Bulletin

NSCP Provides Response to FINRA’s Request for Comment Re: Regulatory Notice 18-08

The National Society of Compliance Professionals (“NSCP”) submits this letter in response to the request by the Financial Industry Regulatory Authority, Inc. (“FINRA”) for comments on a proposed new rule (the “Proposal”) to address the outside business activities of registered persons.

NSCP responded to particular questions posed by FINRA’s Regulatory Notice 18-08. Our response reflects the views of engaged NSCP members who provided feedback to NSCP in response to the Proposal.

NSCP would like to acknowledge Glen Barrentine for his instrumental efforts in coordinating and drafting this response on behalf of NSCP and its membership.


NSCP Webinars: 5/1 – Emerging Technologies – Existing Regulations

Don’t miss this Webinar on Tuesday, May 1 at 3:00 pm EST


Innovation always outpaces regulation. This means that firms have a constant struggle to balance the fear of being left behind by market innovators against the risk of a regulatory action. Join us to understand how to analyze and implement emerging technologies in today’s regulatory framework.

Speakers include:

  • Buddy Doyle, CEO at Oyster Consulting, LLC
  • John (Jack) Hewitt, Partner at Pastore & Dailey LLC
  • Peter Antonucci, Managing Director, Pershing Technology, Pershing LLC, a BNY Mellon Company



MemberVoice: NSCP is meeting with SEC Chairman, Jay Clayton…

It’s time to let your voice be heard!


Last year, you helped us design and define our community vehicle “NSCP MemberVoice”, an anonymous and safe avenue for our Members to share their thoughts, stories, and experiences with regulators, and issues in complying with financial services regulatory requirements.

This year, we’re asking you to use it!

In preparation of our meeting with SEC Chairman, Jay Clayton, on May 21st we want to hear from you so that we can help tell your story.

  • Are there rules that are no longer meeting the objective of investor-protection, by reasonably efficient means, that you would like the SEC to review?
  • CCO liability is still an active topic in our Industry Forums – what’s keeping you up at night?
  • Looking ahead to the second half of 2018, what do you think the Commission needs to address?

You can feel confident that we are providing an outlet for you to voice your experiences without exposing you directly to the regulatory body.



NSCP Webinars: 4/10 – How To Manage Compliance Turnover And Remain Audit Ready

Don’t miss this Webinar on Tuesday, April 10 at 3:00 pm EST


Being prepared for the unexpected, including department turnover, is a challenge all CCO’s must anticipate.

Join us for this presentation that will explore:

  • Most Common CCO Turnover Scenarios
  • Where compliance breakdowns occur in a CCO continuity setting
  • Examples of good and bad CCO turnover planning
  • How to test for audit readiness in the face of compliance turnover
  • Impact of turnover on costs – knowing where everything is and how it works; costs for onboarding new staff
  • How CCO Turnover can present ongoing risks and future liabilities

How technology can help ease the compliance turnover transition