Policy Patty Toolkit 

Making the world a little more compliant one toolkit at a time.


Administrative Changes to the Continuing Education Regulatory Element Programs

Posted on October 2, 2018 at 7:10 PM
Effective December 8, 2018, the content from the S106 and S901 Regulatory Element Continuing Education (CE) Programs will become part of the S101 Regulatory Element CE Program. The S106 and S901 CE Programs will be retired as stand-alone programs. Individuals who previously completed these programs instead will be required to complete the S101 CE Program. The S101 CE Program will include new personalized modules for each of the following representative categories: Investment Company and Variable... Read Full Post »

FINRA Requests Comment on the Effectiveness and Efficiency of Its Rule on the Annual Compliance Meeting

Posted on April 25, 2018 at 4:10 PM

FINRA is requesting comment on its Rule 3110(a)(7) and Supplementary Material .04 (Annual Compliance Meeting) in terms of effectiveness. In sum, the rule requires each registered representative and registered principal to participate, at least once each year, in an interview or meeting at which compliance matters relevant to the representative or principal are discussed. Firms do not have to conduct in-person meetings with each registered person or groups of registered persons to comply with ...

Read Full Post »

Credit Suisse Executives Sanctioned for Asking Assistants to Complete Their Training

Posted on February 21, 2018 at 1:55 PM

Michael Dryden, Jay Kim and Peter Sack, three managing directors at Credit Suisse Securities, asked their respective administrative assistants to complete multiple online continuing education classes on their behalf. Dryden is Credit Suisse Securities’ head of global asset finance, Kim is the head of securitized products, and Sack is the head of Mortgage Finance. None have any disciplinary history with FINRA, the SEC, or any other regulators. These actions took place over a period of 20...

Read Full Post »

FINRA Files Rule Changes to Registered Rep Exams

Posted on February 11, 2018 at 6:00 PM

Proposed Rule Change to Revise the Investment Banking Representative (Series 79) Examination

FINRA filed a rule change with the SEC revisions to the content outline and selection specifications for the Investment Banking Representative (Series 79) examination as part of the restructuring of the representative-level examination program. The proposed revisions also update the material to reflect changes to the laws, rules and regulations covered by the examination and to incorporate the f...

Read Full Post »

Compliance Training and the Board(Sep 2017) - A survey by the SCCE and HCA

Posted on October 15, 2017 at 8:00 AM

The Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCA) conducted an anonymous survey to better understand what types of compliance training is delivered to board of directors. The results were recently published and provide as follows:

• While board training is the norm, 28% reported that the board does not receive compliance and ethics-related training, and for publicly traded companies, 34% of respondents indicated no training is ...

Read Full Post »

SEC approves FINRA consolidated registration rules and requirements

Posted on October 10, 2017 at 2:50 PM

The SEC approved FINRA’s sweeping overhaul of its qualification examinations. Previously, only persons sponsored by a FINRA-regulated firm could take qualification examinations. With the introduction of a “Securities Industry Essentials” examination, FINRA will allow anyone seeking to enter the securities industry whether associated with a member firm or not. Persons who then become affiliated with a FINRA member firm must take a second, more specialized knowledge examinatio...

Read Full Post »