We have been aided in this effort by the broker-dealer
compliance departments of many of our clients. We provide no
"product information" and, in 17 years of providing "conceptual
content" for use by our subscribers, we have never had a
legal issue with any of our content. We do not provide
"timely" material that must be reviewed constantly, but rather
"timeless" concepts that are only subject to tax and
statistical updates. This, plus the fact that only a small
fraction of our content is of an investment and securities
nature requiring FINRA approval, has allowed our clients to
essentially "block approve" the thousands of concepts in
Click here for a list of our client companies and associations.
Use of VSA resources with the public is
subject to the approval of each broker-dealer. For enterprise
sales of 25 or more seats, on request we will provide our
broker-dealers with a "disclaimer coversheet" similar to the
generic one located here.
This "disclaimer coversheet" appears as the first page of all
VSA content meant for public use. Additionally, for large
enterprise editions, we are able to block some objectionable
sections with a custom Main Menu.
The current VSA-provided website (http://fsonline.com/compliance/1-1-2012/) has been reviewed by numerous compliance departments in whose opinion the website content is not product specific, but of a general conceptual nature that is not subject to FINRA review. We rarely change our Website content, except to update it for tax and regulation changes. However, we maintain a list of compliance officers and, upon request, we notify them via e-mail when we institute any changes or updates. We can provide the site on a thumbdrive or .zip file. The Website contains:
Optional content that can be disabled if
you wish includes:
In addition, on the request of a major insurance company and their broker-dealer, we hired Financial Regulatory Services (formerly BISYS Regulatory Services) to have the entire contents of the VSA reviewed and submitted to FINRA (formerly NASD). In August, 2006 Financial Regulatory Services (formerly BISYS) received a Comment Letter from FINRA (formerly NASD) listing the recommended changes to the content. (See Comment Letter below). All fees requested were paid to FINRA and all changes they requested were made at that time. (See Summary below). The only subsequent changes made to the client presentations covered by the comment letter have been tax and statistical updates.
In addition, we hired Financial Regulatory Services (formerly BISYS Regulatory Services) to have the entire contents of the VSA reviewed and submitted to FINRA (formerly NASD) in 2004-2005. All FINRA-recommended changes to the content were made at that time. We subsequently conducted a FINRA "renewal" review by resubmitting selected portions of the VSA content, as recommended by Financial Regulatory Services, in the summer of 2006. The results for that review, together with the changes made to the content as a result of the review, are available below. The only subsequent changes made to the client presentations covered by the comment letter have been annual tax and benefit updates.