Drew Newman and Jonathan Prytherch’s article published by Westlaw Today: Riding the regulatory enforcement train: FINRA issues reminder on supervisory liability for chief compliance officers

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Westlaw Today
05.2022
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Moore & Van Allen (MVA) attorneys Drew Newman and Jonathan Prytherch’s article titled, “Riding the regulatory enforcement train: FINRA issues reminder on supervisory liability for chief compliance officers” was published by Westlaw Today on May 18. The article discusses regulatory enforcement of supervisory liability for chief compliance officers in the context of the Financial Industry Regulatory Authority's Rule 3110.

The article
On March 17, 2022, FINRA issued Regulatory Notice 22-10 (Notice), which reminds FINRA member firms and their associated persons of the scope of supervisory liability for Chief Compliance Officers (CCO). The Notice discusses this liability in the context of FINRA Rule 3110, which among other things, requires FINRA member firms to establish and maintain a system (including written procedures) to supervise the activities of each associated person in a manner that is reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA rules. The Notice covers the scope of individual liability under Rule 3110, the role of a CCO within a member firm, and the factors used by FINRA in assessing liability against a CCO under Rule 3110.

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