One interesting topic at the SIACL conference today was the "issue" of what to do about the producing branch office manager. Some of the panelists from the regulatory side confirmed that the new rules regarding compliance reviews and certifications will not result in a "gotcha" violation and that the regulators understand that many firms will need to feel their way through the new rules.
He confirmed that the examiners have been trained to look for violations of the new 3012 and 3013 requirements, but to also understand and acknowledge reasonable, good faith attempts at compliance.
Good news for many small firms who worked their way through the rules and who will be making their new certifications in April. We have been working with a number of small firms on these issues, which are particularly unique to their situations. Our advice has been to do the best you can, and ask yourself, is there anything more than an examiner could require me to do, in my situation? If the answer is no, you probably have a reasonable, good faith effort at compliance.
