With Great Independence Comes Great Responsibility
My husband and I recently bought our twelve-year-old son his first iPhone. I vaguely recall that at some point we had made a commitment to wait until he was in eighth grade, but things change, middle school came and “everyone had a phone”. Our son is a straight A student, but he likes to walk on the wild side a bit and he doesn’t know what he doesn’t know. The world is suddenly (virtually) at his fingertips and this newfound freedom brings the possibility of making bad decisions that can have lasting consequences. Take for example the in-school suspension he received after being caught by the school counselor sending an “inappropriate” picture during lunch. Whether or not the picture was improper is a moot point: the persons in charge felt it was, the punishment was given, end of story.
I tell this personal story only because it came up during a Remote Supervision panel discussion on which I was participating at the most recent FINRA Annual Conference in D.C. I made a parallel between remote supervision and supervising a tween with a phone. Persons who approach our firm for licensing sponsorship/independent contractor broker-dealer services are highly successful, educated leaders in their industries who are choosing to go independent for the first time. Their decades of experience in many cases, though, are at large investment banks and advisory shops where there are teams of legal, compliance, supervision persons who are functioning behind the scenes and ensuring templates, contracts, communications are all meeting regulatory requirements and best practices. So once these individuals finally take the leap and go for their own newfound freedom of running their own niche firms, they don’t know what they don’t know. They are experts in serving their clients and getting deals done, but the regulatory minutia, the details in a contract or a marketing piece or an obscure conflict is what can cause them trouble down the road. There is great responsibility.
Our entire existence at Burch is to keep everyone out of trouble. That means a non-producing compliance and supervisory team that wholly serves to not only ensure our affiliated professionals meet regulatory requirements but employ best practices that serve the client, that are in place from evaluating years of litigations and arbitrations against professionals in this space. That is where our team is best versed and where we can fit into your processes behind the scenes. No one wants to get in trouble. We’ve worked too hard and there is too much on the line.
When our son got home that afternoon after his punishment, we were able to talk openly about subjectively, thoughtful application of rules, authority and decision making. We talked about the increased responsibility he now faces. We were grateful that this was his introduction to consequences of bad decision making and are hopeful he learned his lesson. At work, we do our best to ensure no one has to learn a lesson with the regulators and that we can get things right the first time. We help to hold some of the responsibility through policies and practices built around your business that directly speak to the applicable rules and proven best practices. At Burch we are here to support you as you may just be going independent. Just please don’t send your clients pictures of fantasy football trophies.