Compliance Predictions and Pressing Questions for 2021

During the webinar A Compliance Officer’s Crystal Ball – One Practitioner’s Predictions for 2021, Compliance Expert Mark A. Egert joined me for his take on what will be the most important compliance concerns of the upcoming year.

Mark also answered some excellent questions during the presentation, and there were a few more that we couldn’t get to because of time. I wanted to take a moment and recap of few of the questions and answers.

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Thoughts on the 2020 FINRA Small Firms Conference

I really enjoyed the opportunity to be an exhibitor at this year’s FINRA Small Firm Virtual ConferenceAlthough the format might have been different this year, the sessions were still filled with the same focus on effective compliance practices for smaller firms.

One of the key themes I heard at the event throughout the sessions was the need for consistency in policies and procedures, and for complete and consistent documentation.

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Pay-to-Play Compliance Key in Record Breaking Election Cycle

The Federal Election Commission (FEC) recently released their Statistical Summary of 18-Month Campaign Activity of the 2019-2020 Election CycleThe data shows that the 2020 election cycle has so far seen record-breaking political donations across the board.

 This unprecedented level of contributions combined with stringent regulations, low donation thresholds, and past history of strict enforcement actions means that Pay-to-Play compliance needs to be a top-of-mind concern for firms of all sizes right now.

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MNPI Remains a High Risk Area for Compliance

Failing to adequately manage Material Non-Public Information (MNPI) remains a high risk area for compliance, as evidenced by recent actions in the U.S. and the U.K. A private equity firm paid $1 million to settle SEC charges for failing to implement effective Insider Trading compliance policies. The FCA published a Decision Notice fining a former CEO £658,900 for market abuse and banning him from future roles linked to regulated activity.

To avoid hefty fines and actions, firms must have comprehensive and actionable policies and procedures around the management of MNPI and insider lists to minimize risk.

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FMSB Final Conflicts of Interest Statement of Good Practice

The FICC Markets Standards Board (FMSB) published the final version of a Statement of Good Practice on the issue of Conflicts of Interest in early October. The guidance is intended to give organizations practical, working level direction and examples to learn from as they determine how to prevent and mitigate conflicts of interest that arise within their enterprises. 

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