Q: What does an independent AML test entail?
A: The independent test of your AML Program includes a review of the current AML program document; an office visit, an interview with the AML Compliance Officer to discuss the firm's policies and program, and an audit of program documents and reports that evidence compliance with NASD Rule 3011. Once those steps are completed, the AML COnsultant prepares a report of the test findings and sends it to the president or CEO of the firm. The average time for the whole test is 10 to 12 hours and is billed at an hourly rate. For more information on the AML program test, call us at 404-303-8840.
Q: How should our firm disclose to our customers how our Business Continuity Plan addresses the possibility of a future significant business disruption and how we plan to respond under Rule 3510?
A: At a minimum, this disclosure must be made in writing to customers at account opening, posted on your web site if you have one, and mailed to customers upon request.
Q: What should our firm do if we are unable to contact the NASD as a result of a business disruption?
A: If you are unable to contact us through your District Office or the main NASD direct dial number, call NASD's Gateway Call Center at (301) 590-6500. This number will be rerouted in the event of a business disruption at our primary call center so that you will be able to reach an operator or receive a recorded instructional announcement in the event of a disruption.
Q: How often should our firm review its Business Continuity Plan under Rule 3510?
A: Rule 3510 requires each firm to conduct an annual review of its BCP. In addition to an annual review, your firm must update its BCP in the event of any material change to your firm's operations, structure, business, or location.
Q: What are a member's requirements for a business continuity plan or BCP?
A: Rule 3510 requires each member to create and maintain a business continuity plan and identifies certain requirements that each plan must address. Each member also must disclose to its customers how its business continuity plan addresses the possibility of a future significant business disruption and how the member plans to respond to events of varying scope. Rule 3520 requires members to designate two emergency contact persons and provide this information to NASD via electronic process. Refer to Notice to Members 04-37 for more information.
Q: How should our firm disclose to our customers how our Business Continuity Plan addresses the possibility of a future significant business disruption and how we plan to respond under Rule 3510?
A: At a minimum, this disclosure must be made in writing to customers at account opening, posted on your web site if you have one, and mailed to customers upon request.
Q: How often should our firm review its Business Continuity Plan under Rule 3510?
A: Rule 3510 requires each firm to conduct an annual review of its BCP. In addition to an annual review, your firm must update its BCP in the event of any material change to your firm's operations, structure, business, or location.
For further information call us today at 1-877-423-4636.
