FINRA's Residential Supervisory Location (RSL) and Remote Inspection Pilot
The landscape for broker-dealers is set to change with the introduction of the Remote Office Rules. These changes, set to take effect on key dates, promise to reshape compliance practices and redefine how firms operate in the post-pandemic era.
May 31, 2024, marked the end of pandemic-related relief for certain requirements on Form U4 and Form BR, necessitates firms to resume obligations, including maintaining updated office of employment addresses and submitting branch office applications.
As of June 1, 2024, broker-dealers can designate certain private residences as Residential Supervisory Locations (RSLs), where supervisory activities can take place. These RSLs provide firms with the ability to oversee their operations remotely, allowing remote work environments while ensuring effective supervision. By conducting regular inspections and risk assessments at these locations, broker-dealers can implement more comprehensive compliance strategies tailored to the evolving nature of remote work.
Starting on July 1, 2024, the Remote Inspection Pilot Program went into effect. This voluntary program allows member firms to fulfill their obligations under Rule 3110(c) remotely, without the need for an on-site visit.
This information comes from Jerry Danielson, Assistant Vice President Field Audit, Lincoln Financial Group Distribution, Andrew Mount, Senior Associate, Eversheds Sutherland (US) LLP, and Jennifer Szaro, Chief Compliance Officer, XML Financial Group, XML Securities, LLC who presented in our NSCP Currents Live Webinar “FINRA's Residential Supervisory Location (RSL) and Remote Inspection Pilot” on April 24, 2024.
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