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Regulators Impose Higher Duty on Financial Providers: Suitability, Know Your Customer and Customer Due Diligence Rules

 
How does the customer rule (2090), suitability rule (2111) and the Financial Crimes Enforcement Network customer due diligence rule (31 CFR 1010.230) apply to your firm or business?FINRA’s know your customer rule (2090) and suitability rule (2111) and the Financial Crimes Enforcement Network customer due diligence rule (31 CFR 1010.230) materially expand the information financial services providers must obtain about their customers. They impose greater duties on these professionals to use that information to serve their customers, monitor the risks that the customers take on and the risks these customers pose to their firms. This topic will summarize these rules, how they apply to financial services providers and some of the practices that can be used to meet these expanded obligations.

Faculty

Morris N. Simkin

Morris N. Simkin

Law Office of Morris Simkin

Agenda

Faculty

Morris N. Simkin

Morris N. Simkin

Law Office of Morris Simkin

  • Experienced and knowledgeable corporate and securities lawyer
  • After serving as Special Counsel with the SEC’s Divisions of Enforcement and Trading and Markets in Washington, D.C. he moved to New York
  • Has been associated with, counsel to or a partner of several major and well known law firms, before establishing his own firm
  • Clients include broker-dealers whom he counsels as to permitted activities and handles SEC and FINRA inspections, investigations and enforcement actions, investment advisers, hedge funds and mutual funds
  • Member of the American Bar Association, Federal Regulation of Securities, Sub-Committee on Market Regulation; member of the New York State Bar Association, Committee on Securities Regulation, Committee on Banking Law
  • Regularly speaks and writes on the subject of the regulation of participants in the capital markets

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