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Broker-Dealer controls regarding retail sales of structured securities products
Among other things, the examinations revealed several significant deficiencies in the areas of suitability and supervision with respect to all of the examined firms’ sales of SSPs to retail investors. Firms failed to maintain and/or enforce adequate controls relating to determining the suitability of SSP recommendations; and failed to conduct both compliance and supervisory reviews of registered representatives’ determinations of customer suitability in the SSPs, as required by their internal controls.
