Webinar

In the face of the COVID-19 pandemic, protecting vulnerable consumers is a regulatory priority. Recently, the SEC has emphasized the need for maintaining market integrity and following controls and procedures. In addition, recent SEC and FINRA actions have shown that enforcing conflicts of interest remains a priority and conduct risk-based inspections will continue to advance.

Addressing Conflict of Interests (COI) that can have an outsized impact on the overall efficacy of a firm’s compliance and ethics program should be a top priority. The danger of poor COI mitigation is not only the immediate impact from individual COIs but also a broader risk to the entire program.

As the June 30 deadline approaches, the SEC has yet to provide an extension to Regulation Best Interest as part of their response to the COVID-19 crisis. Firms must be ready to comply even as they deal with trying to conduct business as usual in a climate of flux and uncertainty.

 As part of their expanded guidance released on April 30, 2019, the U.S. Department of Justice served notice that corporations must be able to demonstrate the impact of their Ethics and Compliance programs—not just that they exist on paper.