August 25, 2015

Change in Membership for a Broker/Dealer

Are you thinking about changing the product lines your broker/dealer offers, adding additional representatives or branch offices beyond the safe harbor provisions, or changing the ownership structure of your firm? Material changes to a broker/dealer’s business or ownership structure require the firm to file a continuing membership application (Rule 1017 application or CMA) with FINRA.

NASD Rule 1017 governs the process for a change in ownership, control, or business operations. FINRA approval is required for a number of different types of changes in firm organization, including certain mergers, acquisitions, asset transfers, and material changes to the business of the firm.

We have been assisting firms with Rule 1017 filings since 2003 and we have several qualified and experienced personnel available to prepare these filings for your firm and act as a liaison with FINRA staff during the approval process. We have successfully completed a number of Rule 1017 filings for a wide variety of firms and understand the factors to be considered by FINRA prior to approval. Our focus is to submit a complete application and we are committed to expediting the approval process.

A Rule 1017 application or CMA must address the same standards as a new broker/dealer application, as applicable. Information that will need to be included in the application consists of, among other factors, a business plan outlining the specific change(s) sought and its impact on the firm’s business; financial projections on how a change in business activities, or additional representatives or new branch offices will affect the firm’s revenues, expenses and net capital; supervisory procedures; and prerequisite experience of the supervisors.

We will assist your team or serve in a full capacity on behalf of the firm to prepare, file, and facilitate Rule 1017 applications. Our services include:

  • Preparing and submitting the Rule 1017 application and Business Plan
  • Ensuring compliance with Rule 1014 standards
  • Determining the structure of the new organization
  • Reviewing the membership agreement
  • Acting as your liaison with the appropriate FINRA District Office to facilitate the application

 
To learn more about our services, contact us or call 1-404-841-1010.