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1211, 2021

DOL Delay: IRAs and Prohibited Transactions

November 12, 2021|Categories: Department of Labor, Registered Investment Advisers|Tags: , , , , , , , , |

Earlier this year, the U. S. Department of Labor (DOL) published their final prohibited transaction exemption regarding investment advice for ERISA plans and IRAs (PTE 2020-02). This exemption is currently effective but allowed for a transition period ending 12/20/2021 for Firms to comply. The DOL recently announced a temporary enforcement [...]

2910, 2021

FINRA Annual Registration Renewal Calendar

October 29, 2021|Categories: Broker-Dealer, Compliance Calendar, FINRA, Registrations|Tags: , , , , , , , , |

This blog serves as a reminder of important dates related to FINRA's 2022 Annual Registration Renewal Program. If you have any state registrations that you do not want to renew in 2022, you must take action by Friday, November 5th in order to avoid being charged on the Preliminary Statement. [...]

2210, 2021

1017 Change in Membership Review

October 22, 2021|Categories: Broker-Dealer, Broker-Dealer Ownership, Continuing Membership Application, FINRA, Rules and Regulations|Tags: , , , , , , , , , , , |

In our 1017 Change in Membership blog we discussed events that would be considered a change in membership that trigger the requirements of FINRA Rule 1017. In this blog we will go over some key areas that firms should cover when reviewing to see if they trigger the application requirements [...]

1510, 2021

1017 Material Change Determination

October 15, 2021|Categories: Broker-Dealer, Broker-Dealer Ownership, Continuing Membership Application, FINRA, Rules and Regulations|Tags: , , , , , , , , , , , |

When a member intends to add a line of business, FINRA has shown that this type of expansion is often a significant event that impacts the firm's supervisory and compliance infrastructure, personnel, and finances. When such an impact occurs, FINRA staff is required to verify that the member continues to [...]

810, 2021

1017 Change in Membership

October 8, 2021|Categories: Broker-Dealer, Broker-Dealer Ownership, Continuing Membership Application, FINRA, Rules and Regulations|Tags: , , , , , , , , , , , |

The Firm should review areas of its business to determine if any current or future changes to the Firm's business may warrant a change in membership application (a.k.a. "CMA" or "1017"). FINRA requires firms to file a continuing membership application (CMA) whenever they seek to expand their operations activities, and [...]

2409, 2021

Website Reviews

September 24, 2021|Categories: Broker-Dealer, Registered Investment Advisers, Supervision|Tags: , , , , , , |

Firms should have appropriately established controls for review, approval, and archiving of all firm related websites and related content. Firms must be able to readily produce all current and historical website content that promotes the firm or any of its covered persons. The firm should establish controls to ensure that [...]

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