Hosted SharePoint platform with built-in workflows for compliance review tasks.
Retains all workflow activity and document libraries in a secure, 17a-4 compliant platform.
Consists of legal modules that integrate workflows to seamlessly manage work product.
Authorized parties can view and collaborate on the documents efficiently.
Streamlines the workflow process between law firms and their corporate clients.
An easy, cost-effective way for small to mid-sized companies to build, organize and manage a compliance program.
Features for all Modules
Unlimited number of uploads
Automatic capture via email to a hosted email address
17a-4’s Smart Reader automatically assigns the associated broker-dealer credentials
Automatic routing for review to determine retention requirements
Automatic alerts to broker-dealers, compliance reviewers and clients
Triggers for approved reports to route to specific libraries
Client logins to access, track, view and download
Automatic disposition after a specified retention period
FINRA 3220 (3221 & 3222) – Gifts, Gratuities and Non-Cash Compensation
- Allows employees to use a templated email to send in information on meals, gifts and seminars;
- Attaches documentation and receipts to the email;
- All information will be captured in a Microsoft SharePoint system that will alert compliance of a new expense;
- Upon receipt of email expense item, a workflow is started tracking the review and categorization of the expense through to approval;
- Information may be exported to Microsoft’s Excel to analyze and incorporate into compliance review reports.
FINRA Rule 3270 – Outside Business Activities of Registered Persons
- Registered persons email information on new Outside Business Activities to the DeskTop
- New emails initiate a Review Task for compliance
- Compliance officers add comments to activities including pertaining discussions and documents along with confidential compliance notes
- Activity restrictions are noted and notification emails regarding the restriction are sent to the Registered Person to accept and obtain directions for future notifications to compliance of any change in the activity
SEC Rule 15a-6 – Registration Requirements for Foreign Broker-Dealers
- Foreign broker-dealer emails new research report into the DeskTop
- New emails initiate a research report review task
- A principal of the U.S. broker-dealer reviews the research report and either identifies compliance issues or approves for U.S. distribution
- Updates to the research report will be treated as versions of the original research report so that change tracking can be captured and retained
- Once approved, research reports can be sent to institutional sales or moved to an approved research report folder
FINRA 2210 and 2211 – Institutional Sales Material Review and Permissioning
- Broker dealers review, retain and provide guidance to registered representatives who, in turn, communicate sales materials to institutional investors
- Processes around the review and approval of institutional sales literature are documented and retained so that registered representatives can easily access
- To download reps must fill in critical information including: intended audience, individual investors and type of presentation
- Source data alerts with instructions for future presentation
FINRA 4530 – Customer Complaints and Filings
- Capture of a complaint either by email or upload to DeskTop.
- Initiates workflows to guide the complaint from an initial response back to the customer through review and resolution
- Reportable complaints are formatted for filing under FINRA 4530
- If complaint evidences or exposes a legal issue, the entire complaint process is transferred to the DeskTop’s litigation portal to provide privilege and access for outside counsel to review
Foreign Corrupt Practices Act (FCPA) – Agent Capture of Gifts and Reimbursements
- Tracking of foreign agent communications, agreements, directives and documentation
- Allows for access and collaboration whenever an agreement expires, a territory is altered or other changes occur in the relationship of the corporation to the agent
- Embedded workflows to reflect the client’s processes and ensure consistent management and reporting of FCPA-related matters
- If issue evidences or exposes a legal issue, the workflow process is transferred to the DeskTop’s litigation portal to provide privilege and access for outside counsel to review
The SEC DeskTop is part of a more comprehensive suite of products, the Law DeskTop, designed to support workflows and workproduct between a corporate law departments and outside counsels.
Compliance DeskTop – supports most aspects of a corporate compliance system including:
- Whistle-blower complaints
- Hotline submissions
- Foreign Corrupt Practices Act (FCPA)
- Reports for Board’s Audit Committee
- Captures and tracks all insurance policies of the corporation
- Provides for annotations and comments by outside counsel
- Tracks leases, licenses, injury reports
- Maintenance records can be emailed into the system and attached to the store’s folder
- Maintenance records, injury reports, insurance claims, lease renewals automatically start a workflow which may include outside parties such as contractors and outside counsel.
- Entire workproduct management system including litigation documents
- Outside counsel can access and review directly on the DeskTop so the documents never leave the secure server
- All review, discussion lists, annotations retain privilege status.
- Multiple parties including court reporters, expert witnesses and other counsel can access the system but are restricted to view only documents expressively allowed by the administrator