FINRA Rule 2211 relates to institutional sales material and correspondence including supervision and review requirements and standards for recordkeeping and content. The SEC Compliance DeskTop has added support for Rule 2211 to complement its other compliance platforms for Rule 17a-4 and Rule 15a-6.
Millbrook, NY- The SEC Compliance DeskTop now provides the platform necessary to adhere to Rule 2211. Under FINRA Rule 2211, broker/dealers are required to review, retain and provide guidance to registered representatives who, in turn, communicate sales materials to institutional investors. As institutional sales materials are not filed with FINRA, the broker/ dealer needs to implement a system that manages the workflows necessary to provide evidence of proper procedures during a regulatory examination.
Managing the distribution of institutional sales materials requires a unique set of information and workflow approvals including, the intended audience, means of distribution, representations of performance or risk, dates of use and sources of third-party data. Processes around the review and approval of institutional sales literature has to be documented and retained. By using the SEC Compliance DeskTop, built upon Microsoft’s SharePoint, compliance officers have a simple, cost-effective means to document compliance and distribute those documents which are available to the broker’s sales teams.
The SEC Compliance DeskTop is a cloud-hosted SharePoint platform which means that registered representatives can easily access the available documents. However, before they can download the documents, they must fill in critical information such as: The intended audience, whether there are any individual investors included in the presentation and the type of presentation. Once this information is provided, the institutional sales document may be downloaded. There is also an alert as to the sources of any data and whether this information has to be communicated as part of the presentation.
In partnership with the Law Department Desktop (www.lawdepartmentdesktop.com), 17a-4 continues to build modules onto the SEC Compliance DeskTop so that broker/ dealers can license these modules on very cost-effective terms. The first compliance module is $2,000 per year and each additional module is $1,000.