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As November approaches, let’s take a look at the upcoming deadlines and educational opportunities that are on FINRA’s compliance calendar for the month. Please note that the calendar does not include all regulatory and filing responsibilities for firms. Therefore, you should check other resources to ensure that your firm does not miss any important deadlines. NOVEMBER 2017 November 1st Form OBS Filings November 2nd District Compliance Event: District 9 (Washington, DC) Short Interest Reporting November 7th AML Half-Day Seminar (Boca Raton, FL) November 8th Small Firm Conference Compliance Outreach Program for Municipal Advisors Customer Margin Balance November 12th -17th Wharton Read More....
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As technology continues to advance, the Financial Industry Regulatory Authority “FINRA”) must address how certain regulations will be interpreted as it relates to social media platforms. FINRA Rule 4530 requires firms to promptly report to FINRA, no later than 30 calendar days, after it knows or should have known that the firm or an associated person of the firm is the subject of any written customer complaints involving allegations of theft or misappropriation of funds, securities, or of forgery. Under the rule, a customer is defined as any person, other than a broker or dealer, with whom the member has Read More.... -
As mentioned in our previous post, What is on the Series 7 exam, the FINRA has restructured the examination process and implemented a new exam, the Securities Industry Essential exam (“SIE”). On October 1, 2018, the SIE exam will become a prerequisite to all of the FINRA’s representative-level qualification exams (“rep-level exams”). PURPOPSE OF THE SIE EXAM The purpose of the SIE exam is to eliminate the testing of duplicate information that is provided on the rep-level exams. To accomplish this, the duplicate content will be pulled out of the rep-level exams, and will be tested only on the SIE Read More....
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Supervisory System A firm’s supervisory system serves as its foundation to building a robust compliance program. It is important that firms tailor their supervisory system to their business activities, how the firm is organized and operated, regulatory requirements, and other key considerations determined by the firm. The minimum requirements of a supervisory system include: Designating Principals Responsible for Supervision; Designating Offices of Supervisory Jurisdiction; Assigning Supervisors for Registered Representatives and Designating OSJ/Non-OSJ Branch Supervisors; Determining Qualifications of Supervisory Personnel; Annual Compliance Meeting; and Review of Supervisory System. Written Supervisory Procedures Developing a supervisory system is the first step. Next, Read More....
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What are Soft Dollars? In asset management and the securities industry, soft dollars refers to an asset manager’s use of commissions to pay for investment research and brokerage services. Commissions Commissions are defined as a markup, markdown, commission equivalent or other fee paid by a managed account to a dealer for executing a transaction where the fee and transaction price are fully and separately disclosed on the confirmation and the transaction is reported under conditions that provide independent and objective verification of the transaction price subject to self-regulatory organization oversight. Safe Harbor Section 28(e) of the Exchange Act provides a Read More....
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For Part 1, please see Large Trader-Rule 13h-1 (Part 1). Part 2 A large trader is required to file a Form 13H Initial Filing promptly after effecting aggregate transactions equal to or greater than the Identifying Activity Level threshold. After initial filing, Rule 13h-1(b)(1)(ii) specifies that an annual filing must be made within 45 days after the end of each full calendar year. The SEC will provide large traders with a large trader identification number (“LTID”). The LTID must be provided to each broker-dealer effecting transactions on behalf of the large trader. Each account that a large trader exercises investment discretion Read More....
