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145. Cybersecurity policy is not being followed including any mandated testing
Our policy is to periodically review our cybersecurity and update as needed. If we discover our
cybersecurity policies are not being followed, our policy is to retrain the employees and ensure they follow
procedures. .
Solicitors
146. Hiring a solicitor that is disqualified
Our policy is to not hire solicitors.
147. Compensation paid to solicitors not complying with Solicitors rule and state regulations
Our policy is to not hire solicitors.
148. Inadequate disclosure relating to the use of solicitors
Our policy is to not hire solicitors.
149. Solicitor not handing out a Solicitor’s Disclosure Statement
Our policy is to not hire solicitors.
Policies and Procedures
150. Policies and Procedures not applicable to firm business
Our policy is to periodically review our P&P and update as needed. If we discover that our P&P
has not reviewed or updated, our policy is to have them reviewed and updated as soon as possible.
151. Policies and Procedures not being updated when needed
Our policy is to periodically review our P&P and update as needed. If we discover that our P&P
has not reviewed or updated, our policy is to have them reviewed and updated as soon as possible.
152. Updates to Policy and Procedures manual not distributed to employees
Our policy is to distribute any P&P updates to employees. If we discover that our P&P has not
been distributed, our policy is to distribute it as soon as possible.
153. Annual reviews not being completed and documented
Our policy is to have an annual review. If we discover that we have not had an annual review,
our policy is to schedule it as soon as possible.
154. On-going monitoring and testing not being completed
Our policy is to periodically review our P&P and update as needed. If we discover that our P&P
has not been tested, our policy is to test it as soon as possible.
