NSCP Currents On Demand
NSCP Currents’ history dates back to the 1980s and we are proud of how it has progressed to the premier compliance publication of the financial services industry today. Since NSCP’s incorporation in 1987, NSCP Currents has evolved in both content and format, yet continues to provide invaluable information to the compliance community. From a paper publication which was mailed to NSCP members, to a digital PDF published through email, NSCP staff, along with members of the Publications Committee, have ensured that NSCP Currents has remained “current."
Continuing its evolution, NSCP Currents articles are now published individually and are available to members on demand. In addition to the high-level articles and resources NSCP members value and expect, NSCP has launched NSCP Currents Live monthly webinars featuring industry hot topics. Recordings of all NSCP Currents Live webinars are published alongside written articles on NSCP Currents On Demand.
NSCP Celebrates... Juneteenth
Juneteenth, observed annually on June 19, commemorates the end of slavery in the United States. It marks the day in 1865 when Union troops arrived in Galveston, Texas, and finally informed enslaved African Americans of their freedom—more than two years after the Emancipation Proclamation had been signed. Known over the years as Jubilee Day, Freedom Day, or Emancipation Day, Juneteenth has long been celebrated by African American communities as a moment of reflection, resilience, and joy. ... Continue Reading
06-18-2025
Risks a CCO May Encounter Beyond the Compliance Program – Perspectives from a Chief Compliance Officer
By Elizabeth Hansen
Exploring Key Areas of Concern Chief Compliance Officers (CCOs) in the financial services industry bear a multitude of risks that extend beyond their firms’ compliance program. Various activities and situations can amplify these risks, necessitating vigilance and proactive measures from CCOs. This article explores three critical areas that may exacerbate the risks for the Chief Compliance Officer. Furthermore, distinctions have been made between references to the CCO and ... Continue Reading
06-12-2025
NSCP Comment Letter FINRA Regulatory Notice 25-04 - May 27, 2025
The National Society of Compliance Professionals (“NSCP”) submits this letter in response to the request by FINRA in Regulatory Notice 25-04 for comments related to FINRA’s efforts to modernize its rules. We appreciate this opportunity to provide feedback as well as FINRA’s past efforts to seek ... Continue Reading
06-05-2025
Currents Live Webinar - "Navigating the Evolving Cyber Landscape and Regluation S-P"
Speakers: Amber M. Allen, Counsel, Eversheds Sutherland (US) LLP, Bryan Smith, SVP - Complex Investigations and Intelligence (CII), FINRA, and Pam Gelormini, VP, Sr. Director and Privacy Officer, MFS Investment Management .... View Webinar
05-28-2025
How to Implement an IA AML Program
By Melissa Starr and Craig Watanabe
The Regulatory Imperative The FinCEN Anti-Money Laundering (“AML”) rule for investment advisers (“IAs”) and exempt reporting advisers has a compliance date of January 01, 2026. In the final rule, FinCEN stated it would separately propose Customer Identification Program (“CIP”) and Customer Due Diligence (“CDD”) rules. The CIP rule was proposed jointly with the SEC on May 21, 2024, and is still pending, subject to a regulatory freeze. FinCEN has not .... Continue Reading
05-22-2025
NSCP Celebrates… Asian American & Pacific Islander Heritage Month and Mental Health Awareness Month
Asian American and Pacific Islander Heritage Month
This May, NSCP recognizes the many contributions of Asian Americans and Pacific Islander Americans. While you are busy organizing your compliance files, why not check out some of these great resources in celebration of this community! NSCP is also proud to highlight SEC Commissioner, Mark T. Uyeda, as one Asian Pacific American role model blazing trails in financial services regulation. Commissioner Uyeda joined the SEC in 2006, serving .... Continue Reading
05-08-2025
Currents Live Webinar - “Crypto: A New Hope for Compliance Professionals”
Featuring Sam Callahan, Vice President, Battery Finance, Iqan Fadaei, Associate, Michael Best & Friedrich LLP, and Owen Rapaport, Former Executive Director, StarCompliance ... View Webinar
05-01-2025
Understanding the GIPS® Standards Guidance Statement for OCIO Portfolios
By Janice Kitzman, Natalia Taylor, and Omkar Bhapkar
The investment world is always evolving, and with it, the need for compliance oversight and standardized guidance to evolve as well. This article will provide an overview of which portfolios are and aren’t covered by the new Global Investment Performance Standards (GIPS®) Guidance Statement for Outsourced Chief Investment Officer (OCIO) Portfolios. Many of the OCIO challenges ring true for retail wealth managers, but this guidance statement .... Continue Reading
04-24-2025
SEC Staff Issues New FAQs on the Marketing Rule, Providing Investment Advisers with Flexibility and Clarity
By Issa Hanna and Jose Gerez
On March 19, 2025, the Securities and Exchange Commission’s (the “SEC”) Division of Investment Management staff (the “Staff”) issued two new Frequently Asked Questions (“FAQs”) focused on Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) (the “Marketing Rule”). [1] The FAQs focus on two specific areas: (1) the display of the gross performance of an extract in an advertisement without including corresponding net performance of the extract; and (2) the presentation in an advertisement of one or more gross characteristics of a portfolio or investment that does not include .... Continue Reading
04-17-2025
Trade Surveillance in Perspective
By Jeremy Dela Cruz and Craig Watanabe
“You get what you inspect, not what you expect.” – Louis V. Gerstner Jr., former CEO of IBM
Beyond lofty expectations, upholding standards of care and conduct requires ongoing inspection and verification, especially in capital markets. The standard compliance objective is “creating a reasonably designed compliance program to prevent, detect, and correct securities violations.” An alternative formulation would be: “to create a compliance .... Continue Reading
04-10-2025
NSCP Celebrates... National Volunteer Month
In honor of National Volunteer Month, NSCP would like to thank all of our volunteers! We greatly appreciate you taking the time to share your invaluable expertise and experience with your fellow NSCP members. Your volunteer efforts not only benefit the NSCP community, but the entire compliance industry as a whole. Thank You 2025 NSCP Volunteers! .... Continue Reading
04-03-2025
FINRA in 2024: Cinderella or Top Dog? An analysis of FINRA’s disciplinary actions
By Brian Rubin, Adam Pollet, and Amanda Oliveira
Coach Norman Dale: If you put your effort and concentration into playing to your potential, to be the best that you can be...
Securities fans may disagree with Coach Dale. Every spring, securities lawyers and compliance professionals keep their eyes peeled... Continue Reading
03-27-2025
NSCP Currents Live Webinar - “You’ve Identified Possible Financial Exploitation of Your Client – Now What?”
Featuring Tara Ambrose, VP, Client Risk Prevention, RBC Wealth Management... View Webinar
03-26-2025
Meeting Goals
The Compliance Professionals at NSCP hope to engage in a dialogue with FINRA’s Examination Management with the purpose of better understanding each other’s objectives, advancing our shared goals and acknowledging the challenges each other face in achieving those goals. We hope that this is not the end of the conversation, but the beginning of a collaborative dialogue. Continue Reading
03-20-2025
By Ana Petrovic, Rose Kaufman, and Kiran Krishnan
As investment adviser (IA) compliance teams dive headfirst into the 2025 compliance season for Form ADV updates and custody audits, there is no better time to revisit the rule that keeps resurfacing on the U.S. Securities and Exchange Commission’s (SEC) radar – Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (Advisers Act) – commonly referred to as the Custody Rule... Continue Reading
03-13-2025
March is Women’s History Month, a time to recognize and honor the countless achievements and contributions of women throughout history. It’s a month dedicated to reflecting on the trailblazing women who have shaped our world, as well as those who continue to inspire and challenge the status quo today... Continue Reading
03-06-2025
By Brian Rubin
On Friday, January 17, 2025, near the end of Chair Gary Gensler’s tenure, the Securities and Exchange Commission brought about 20 enforcement actions, including two notable cases against dually registered firms for their cash sweep programs... Continue Reading
02-27-2025
Featuring Gwen Williamson, Partner, Faegre Drinker Biddle & Reath LLP and Scott Bennewitz, CCO/CFO... View Webinar
02-26-2025
By Michael Cocanower
With the SEC’s announcement of rule amendments to Regulation S-P which became effective August 2, 2024, the clock began ticking toward a compliance deadline of December 3, 2025 for large firms (1.5B+ AUM)... Continue Reading
02-20-2025
By Paul Felsch, JD
EXECUTIVE SUMMARY Outsourcing of key services continues to be on the rise, with some 2024 studies showing that certain market registrants plan to increase the level of outsourcing between 25% and 50% over the next three years... Continue Reading
02-13-2025
By Takesha Pollock
Black History Month is a time to honor and celebrate the achievements and contributions of African Americans. Although officially recognized in the month of February, NSCP celebrates the countless achievements and contributions of African Americans all year round... Continue Reading
02-06-2025
Featuring Brad Busscher, Chief Administrative Officer and General Counsel, Insperex; Bridghet Donato, Chief Compliance Officer, Peaceable Street Capital; and Daniel Kahl, Partner, Investment Funds Practice Group, Kirkland & Ellis LLP... View Webinar
01-30-2025
By Robert Tull CPA CFE CCEP CSCP FRM CPC
The SEC’s 2025 Examination Priorities highlight the staff’s focus on the effectiveness of adviser compliance programs... Continue Reading
01-23-2025
Featuring NSCP Board Chair, Patrick Hayes, NSCP Executive Director, Lisa Crossley and NSCP COO/Deputy Executive Director, Melissa Loner ... View Webinar
01-16-2025
By Brian Rubin and Max Miseyko
The answer, my friend, is blowin’ in the wind. The answer is blowin’ in the wind. – Bob Dylan
Regulators at both the SEC and FINRA have stated that they rarely charge CCOs for compliance failures, so when they do, it sends shockwaves... Continue Reading
01-09-2025
By Lauri London
The SEC recently fined GQG Partners, a Florida based investment adviser, $500,000 for language in agreements that didn’t provide Whistleblower protection... Continue Reading
01-02-2025
Featuring Patrick Gushue, Acting Director, Corporate Whistleblower Awards (CWA) Pilot Program, DOJ and Lisa Colone, Chair, Securities Enforcement, CSG Law... View Webinar
12-12-2024
By Ethan Corey and Clifford Kirsch
On July 26, 2023, the SEC issued a release proposing a sweeping set of rules that would regulate the use of AI by SEC-registered investment advisers... Continue Reading
12-05-2024
By Jeremy McCamic
On September 9, 2024, the SEC announced settled charges against nine registered investment advisers for violations of Rule 206(4)-1... Continue Reading
11-27-2024
Featuring Jeff Gearhart, Susan Light, and Daniel Wright... View Webinar
11-21-2024
By Anna Schnitkey
As the new year approaches, now is a crucial time of year for investment advisers to ensure that their compliance programs are up to speed... Continue Reading
11-14-2024
By Takesha Pollock
November marks Native American Heritage Month, a time to recognize and celebrate the rich history, culture, and contributions of Native Americans... Continue Reading
11-07-2024
By Paul Felsch
With the ever-increasing fervor around the use if AI/GenAI, several colleagues have shared with me over the past several weeks... Continue Reading
10-31-2024
By Michelle L. Jacko
Effective November 13, 2000, the U.S. SEC adopted Regulation S-P to manage the use and protection of consumer non-public data by financial institutions... Continue Reading
10-24-2024
By Ted McCutcheon, Shawn Bostic and Melissa Starr
Many organizations don’t focus enough on junior officers’ development. This deficiency not only impacts performance, but also retention... Continue Reading
10-17-2024
By Madison Dewey
As cyber criminals have become more advanced, authentication has emerged as a safeguard to protect systems and users against threats... Continue Reading
10-10-2024
By Takesha Pollock
October is a significant month for LGBTQ+ History and National Disability Employment Awareness. These observances reflect the progress, challenges, and contributions of two vital communities within our society... Continue Reading
10-03-2024
Featuring Takesha Pollock, Kona Mann, and Issa Hanna ... View Webinar
09-25-2024
By Craig Watanabe
Hackers are constantly evolving and cyberattacks are becoming more sophisticated. Until recently, email accounts secured with two-factor authentication (“2FA”) were very secure. Unfortunately, this is no longer the case... Continue Reading
09-19-2024
By Kim Cash and Janice Kitzman
In the weeks since the U.S. Fifth Circuit of Appeals struck down the SEC’s Private Fund Advisors Rule (PFAR)... Continue Reading
09-12-2024
NSCP recognizes the many contributions of Hispanic and Latinx Americans during this annual celebration... Continue Reading
09-05-2024
Featuring Chad Nichols, Bart Layton, Kelly Kosciuszka, and others... View Webinar
08-28-2024
By Brian Rubin and Joseph Szczesny
If you think about it, Walter White, the star of the 16-time Emmy award-winning drama series Breaking Bad, was similar in a lot of ways to individual representatives who were sanctioned by the Securities and Exchange Commission (SEC) and FINRA. They all (presumably) started out with a desire to do the right thing... Continue Reading
08-22-2024
As we eagerly approach our much-anticipated 2024 NSCP National Conference, we are happy to present to you this special edition of NSCP Currents... Continue Reading
08-15-2024
By Craig Watanabe
There is great utility for a compliance program to look at risks from different angles and through different lenses. The concept of risk is well studied by academics and others in diverse fields such as management and even politics... Continue Reading
08-08-2024
By Adam Schaub
An often-asked question about the use of Artificial Intelligence (“AI”) is “Will it take my job?” In 2022 Elon Musk announced a humanoid robot named Optimus intended to replace humans in jobs that are considered dangerous or where there are labor shortages... Continue Reading
08-01-2024
Featuring India Williams, Partner and Co-Chair, ESG Risk and Investigations, Katten Muchin Rosenman LLP, Josh Jones, Chief Compliance Officer, Vulcan Value Partners, and Justin McGuffee, Compliance Officer, AVP, MFS Investment Management... View Webinar
07-24-2024
By Brian Rubin
If you are new to securities compliance, your head sometimes spins: What is an RIA v. an IAR v. an IRA v. an AIR? (We made up the latter.) And is “IRA” pronounced “eye” “are” “aaayyy”... Continue Reading
07-18-2024
By Melissa Starr and Craig Watanabe
As is often the case in compliance, laws enacted by Congress lead to rules enacted by regulators, which in turn leads to firms implementing policies and procedures... Continue Reading
07-11-2024
By Patrick Hayes
As I reflect on my first couple months as the NSCP Board Chair, I am humbled by the outpouring of support from the Staff, the Board of Directors, and the entire NSCP membership... Continue Reading
07-09-2024
By Shannon Bean
In July of 1990, the United States passed the Americans with Disabilities Act, which is a civil rights law that prohibits discrimination based on disability... Continue Reading
07-03-2024
By Marc Gilman and Aakash Alurkar
For the compliance officers operating in this golden age of collaboration applications, it is crucial to stay informed about the emerging feature sets of platforms like Zoom, Slack, Webex, and Microsoft Teams... Continue Reading
06-27-2024
Featuring Jason Berkowitz, Chief Legal & Regulatory Affairs Officer, Insured Retirement Institute (“IRI”), David Kaleda, Principal, Groom Law Group, and Jane Riley, Chief Compliance Officer, The Leaders Group... View Webinar
06-25-2024
By Craig Watanabe
“Fiduciary” has multiple definitions. The one most of us are familiar with is the common law fiduciary, which applies to registered investment advisers... Continue Reading
06-20-2024
By Christopher J. Kelly and Miriam Lefkowitz
Compliance professionals frequently incorporate interpretive guidance issued by SEC and FINRA Staff as they develop and maintain their compliance programs... Continue Reading
06-13-2024
By Shannon Bean
All across the country, June is celebrated as Pride Month, and NSCP is proud to be a participant in that celebration... Continue Reading
06-06-2024
By Fred Reish
The Department of Labor (DOL) has issued its final regulation defining fiduciary advice together with related exemptions... Continue Reading
05-30-2024
Featuring Pete Driscoll, Liz Legacy, and Paul Tyrell
Featuring Pete Driscoll, Partner, PwC, Liz Legacy, Executive Director, CCO – CUSO SPF, Atria Wealth, and Paul Tyrell, Partner, Sidley Austin LLP ... View Webinar
05-22-2024
By Craig Watanabe and Ryan Smith
On January 11, 2024, the SEC approved 11 spot Bitcoin ETFs for trading. Importantly, these spot Bitcoin ETFs will own Bitcoin directly... Continue Reading
05-16-2024
By Melissa Starr, Jane Riley, Craig Watanabe and Miriam Lefkowitz
Have you ever had to explain what we do as Compliance Officers to someone who knows little to nothing about compliance? Continue Reading
05-09-2024
By Takesha Pollock
In our collective journey towards progress and inclusivity, it’s imperative to acknowledge and celebrate the rich tapestry of contributions made by the Asian American and Pacific Islander (AAPI) community... ... Continue Reading
05-02-2024
Featuring Jerry Danielson, Andrew Mount, and Jennifer Szaro
Featuring Jerry Danielson, Assistant Vice President Field Audit, Lincoln Financial Group Distribution, Andrew Mount, Senior Associate, Eversheds Sutherland (US) LLP, and Jennifer Szaro, Chief Compliance Officer, XML Financial Group... ... View Webinar
04-25-2024
By Andrew T. Mount and Erin Preston
The COVID-19 pandemic changed how broker-dealers serve customers and supervise associated persons... ... Continue Reading
04-18-2024
By Melissa Starr and Craig Watanabe
The USA PATRIOT ACT of 2001 was passed by Congress following the wake of the terrorist attacks on September 11, 2001... ... Continue Reading
04-11-2024
Featuring Genna Garver, Igor Rozenblit, and Scott Weisman
Featuring Genna Garver, Partner, Troutman Pepper; Igor Rozenblit, Managing Partner, Iron Road Partners; and Scott Weisman, Partner, CCO, Senior Regulatory Counsel, Bain Capital, Boston Office... ... View Webinar
03-27-2024
By Christopher J. Kelly
A little-known provision of Regulation SHO is getting increased attention from regulators. Recently, regulators have signaled that they will be taking a close look at broker-dealers’ invocation of the so-called “bona fide market-maker” exception... ... Continue Reading
03-21-2024
By Craig Watanabe
The Body of Knowledge for Leadership and Management... This article will offer practical suggestions on how to apply sound leadership and management concepts specifically to managing a Compliance Department... ... Continue Reading
03-14-2024
By Takesha Pollock
Since 1995, March has been designated as Women’s History Month. Women’s History Month gives us the opportunity to formally celebrate the women who have paved the way for future women leaders in our industry... ... Continue Reading
03-07-2024
Featuring Myles Blechner, Kim Chapman, and Patricia (“Trish”) Flynn ... View Webinar
02-28-2024
By Jessica LeBlanc
In January 2024, the Financial Industry Regulatory Authority (FINRA) and the MSRB filed their proposals with the SEC to decrease the time to report fixed income securities transactions from fifteen minutes to one... ... Continue Reading
02-22-2024
By Brett Lassoff
It was early in my career as a financial exploitation compliance professional, and I was on a conference call with a 94-year-old life insurance policyholder and various children and grandchildren... ... Continue Reading
02-15-2024
By Jocelin Martinez
As a compliance professional, you’re responsible for disseminating important regulatory information via training sessions and presentations... ... Continue Reading
02-08-2024
By Takesha Pollock
Black History Month is a time to honor and celebrate the achievements and contributions of African Americans... ... Continue Reading
02-01-2024
Featuring Patrick Hayes, Rosa Licea-Mailloux, and Brian Rubin... ... View Webinar
01-24-2024
By Janice Powell and Craig Watanabe
What is the biggest hurdle to your compliance program? How do you incorporate changes to the program?... ... Continue Reading
01-18-2024
By Amber Allen, Cameron Funderburk and Manning Peeler
Developing a Diversity, Equity and Inclusion (“DEI”) program at your organization can have many substantial benefits... ... Continue Reading
01-11-2024
By Melissa Loner
As we move into the New Year, I want to celebrate some of the accomplishments we’ve had and give a glimpse of what to look forward to... ... Continue Reading
01-05-2024
By Jeff Blumberg
Those of you who were able to join us at the 2023 National Conference in Dallas have already heard some of this over lunch... ... Continue Reading
01-04-2024