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Regulators

FINRA Launches Sweep Exam

October 27, 2016

FINRA announced the theme of ts Sweep-Examination-of-the-Month.  For October, the regulator will conduct an inquiry regarding incentives for broker-dealer (B/D) employees to: (i) promote bank products of the affiliate or parent company to B/D retail customers through referrals or direct sales;  (ii) add features - e.g., securities-based loans, credit or debit cards, or checking accounts - to B/D retail customer accounts;  and, (iii) open additional B/D retail accounts for customers.  Together referred to as "cross-selling programs."

 

For the exam period running from 1/1/11 through 9/30/16, FINRA requested supporting documents for the following categories:  

 

  • Description of firm's cross-selling programs..
  • Description of content and method of communication to employees of information regarding cross-selling programs.
  • Description of monetary and non-monetary benefits to employees related to cross-selling programs.
  • Description of metrics used to track and evaluate employees' performance related to cross-selling programs and the application of those metrics to performance ratings, promotion and termination.
  • List of employees terminated or disciplined for not meeting production goals or for engaging in improper activities related to cross-selling programs.
  • List of B/D retail customers who: (i) had accounts opened on their behalf without authorization, (ii) had features added to their accounts without authorization, (iii) had bank products of an affiliate/parent added to their accounts without authorization or (iv) were reimbursed (include the reimbursement amount) due to improper activities related to cross-selling programs. Include a description regarding how firm identified the customers represented in this list.

 

[Click link for complete details.]