Periodically regulatory organizations conduct examinations of branch and non-branch locations of registered broker-dealers. These examinations can be random or specifically selected based on regulatory “red flags.” In any event, such examinations are sometimes conducted on an unannounced basis. In the event of the commencement of such an examination, the Designated Supervisor must immediately contact the Compliance Department. Personnel should request identification (ID badge, business card, etc.) prior to contacting the Home Office so that the names of the examiners and their organization can be communicated to IFA’s Compliance Department.
If a regulator asks to interview a registered person, that person must immediately contact his/her supervisor and participate in the interview only in the presence of a representative of ING U.S. Legal Services, the CCO or their designee.
Offices should fully cooperate with any requests by the examiners to inspect routine books and records. All written communications and all written or oral requests for information must be communicated immediately to IFA’s Compliance Department. This communication must be made prior to responding to the request. Under no circumstances should an Associated Person of IFA respond to an inquiry without the approval of the Legal Department and the CCO.
Subsequent to the examination, any formal or informal communication from the regulator requesting additional information or communicating findings of an examination must be immediately forwarded to IFA’s Compliance Department.
Copies of all correspondence to or from regulators in connection with the office examinations must be maintained in a readily accessible location in the branch office’s files for a minimum of four years from the date of the most recent document in the file (e.g. the response letter). Copies of any documentation provided to or received from regulators should be forwarded to IFA’s Compliance Department. All records pertaining to regulatory examinations will be maintained in the Home Office for a period of at least four (4) years.
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