Compliance Training 2022-10-10

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Across
  1. 3. The signed contract that ICW has with our Clients; outlines our services, responsibility, liabilities and limitations
  2. 5. A type of incident that may require Incident Response Team activation; can include cybersecurity and physical access
  3. 8. The processing of fees paid by Clients; done monthly in advance based on prior month-end values
  4. 9. A word or passphrase that is used to secure logins; must be a minimum of 16 digits containing uppercase, lowercase alpha, numerical and special characters
  5. 10. A Client’s written dissatisfaction with the acts of a Supervised Person that demands rectification
  6. 14. A __________ Client has been defined by the SEC ad being older than 62; is subject to additional monitoring to detect exploitation and abuse
  7. 15. The set of documents consisting of the Form CRS, ADV Part 2A and 2B; provides information about the Firm's advisory services, business practices, professionals, policies and any actual and potential conflicts of interest, among other things
  8. 16. The only Firm-approved social media platform
  9. 17. Asset Disposal and ___________________; the proper process of removing Firm Information, physical assets, mobile devices and business equipment; must be logged
  10. 18. A Federal Rule that governs the physical or electronic access and/or control of Client assets; includes the acceptance of cash or cash equivalents, and access to Client’s username and password
Down
  1. 1. ___________ Theft; a growing issue aimed at mimicking Clients in order to obtain financial control
  2. 2. Actual or hypothetical results presented to Clients; is under new scrutiny via the Marketing Rule
  3. 4. Data __________________; organized into tiers based on data sensitivity; includes Firm Information, NPI, and Public Information
  4. 6. The acronym of a Federal regulatory law that requires the reporting of cash deposits over $10,000 and OFAC screening; this is one reason why ICW does not accept cash
  5. 7. The act of governing such Persons in a way that reasonably prevents violations of policies and procedures; an over-watch of conduct and adhesion to duties
  6. 11. The absence of a hard-wired connection to the Firm’s network; using such access must be done via the Firm’s VPN and use of public connection is prohibited
  7. 12. Penetration and _________________ testing; used to test the effectiveness of the Firm’s network and data security
  8. 13. Supervised Person trading meets this when personal trading is completed in the last hour of the day, is less than 4% of the account’s value, or consists of shares that were held longer than 90 days