Broker-Dealer Compliance
There have been no more challenging times than the present for compliance and supervisory professionals at financial services firms.  Between the consolidation of NASD and NYSE rules, new rule making, and the increased regulatory scrutiny on broker-dealers brought on by investment-related scandals and failures, firm managers are struggling to afford appropriate staffing and keeping their businesses compliant.

Diane K. Golbeck, PLLC can help in the following situations:

  • Assisting firms with compliance and supervisory procedures.
  • Designing more effective and compliant supervisory structures.
  • Providing objective evaluations of existing procedures to ensure they are current.
  • Testing supervisory systems to ensure adequacy
  • Testing actual practices to ensure consistency with procedures.
  • Providing regulator-ordered compliance consulting and reports.
  • Conducting risk-based main office or departmental audits.
  • Providing a due-diligence analysis of new brokers or branch offices.
  • Designing plans for enhanced supervision of sales persons.
  • Designing “active account” procedures, including activity letters and client contact guidance.
  • Conducting “discussion-based” on-site audits of OSJs, branch and non-branch locations.
  • Conducting independent AML audits.
  • Testing and preparation of Rule 3012 and 3130 Reports in advance of CEO Certifications.
  • Providing advice regarding reporting issues.
  • Reviewing and responding to customer grievances and complaints.
  • Providing “special situation” on-site audits.
  • Assistance in responding to regulatory requests for information. 

Fees charged for services may be on an hourly or a flat fee basis, as agreed upon by the parties. 

​Regulatory Representation
When you are asked to respond to a request for information, or are “requested” to appear for an on-the-record interview (“OTR”) or deposition, you may well be facing the beginning of a long and frustrating experience that may result in disciplinary action against your firm, or you, or both.

Having prepared dozens of cases as a FINRA investigator and attended and deposed numerous industry persons for potential disciplinary action, I am uniquely qualified to assist in the following areas:

  • ​Responding to requests for information.
  • Responding to a Wells Notice.
  • Intensive preparation for an OTR.
  • Attending and defending your interests at an OTR or deposition.
  • Negotiating settlements.Assisting in the defense at hearing. 

​​Fees charged for these services will be on an hourly basis, at a fee agreed upon by the parties.


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