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All I Want for the New Year is . . .



Well, the New Year is upon us, giving us the opportunity to pause, reflect, and be thankful that we’ve made it through a pretty eventful year.


And, for those who live in the world of compliance, what a year it has been! 2017 brought about unprecedented change – and that change will likely accelerate into 2018, which will give many a reason to dive into the eggnog over the holidays. Having done so, I went to sleep last night, and my mind wandered among visions of sugar plums and deregulation, and I wondered – what do compliance officers want for Christmas?


My first thought, as I nestled all snug in my bed, is “Why don’t we have Christmas every day?” – and then it appeared: Senate bill 2155, the bill for Economic Growth, Regulatory Relief and Consumer Projection Act (https://www.congress.gov/115/bills/s2155/BILLS-115s2155is.pdf). Among its many blessings would be a significant roll-back in provisions of the Dodd-Frank Act, which would “modernize regulations in a way that make sense for small financial institutions, benefiting consumers and encouraging economic growth,” according to Senate Banking Committee Chairman Mike Crapo. Ah, yes, Christmas every day!


I then drifted off, soared across new-fallen snow, and found myself in London. I reached over and found the Daily Mail dated January 1, 2018, and with wondering eyes absorbed the day’s headline: “New MiFID II Implementation Date Postponed Until 2019”.  I danced with joy, no longer worrying about how I would capture and review voice recordings, face-to-face transcripts, social media posts, and text messaging for each and every transaction conducted by my firm. Like a warm blanket, I now felt comforted in my decision to rely upon the technologies acquired by my predecessor in 1998 to meet the market transparency demands of 2018.

But the joy was short lived, and I was now enveloped into the cold and darkness of Brussels, standing alone in front of the European Data Protection Board. The Commissioner, with a wink of his eye and a twist of his head, soon gave me to know I had nothing to dread. “In the matter of violating the provisions of GDPR, I find you not guilty. You’re a Data Privacy Star!”

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