Blog
SEC Releases New RIA Form ADV Filing Requirements Effective October 2017
Securities and Exchange Commission (SEC) adopted amendments to Investment Advisers Act rules in August 2016 that will result in significant changes to Form ADV for advisory firms working with SMA’s (Separately Managed Accounts). The additional data will help the SEC focus on examining firms more often that present the greatest [...]
2017 Examination Priorities for RIA’s and BD’s
The Office of Compliance Inspections and Examinations (“OCIE”) of the Securities and Exchange Commission (“SEC”) continues another year of exam priorities for its Registered Investment Advisors (“RIA”) and Broker-Dealers. OCIE are the “eyes and ears” of the SEC, and its exams are used by the SEC to inform rule-making initiatives, [...]
FINRA Updates Private Placement Filer Form Pursuant to FINRA Rules 5122 and 5123
FINRA has updated the form that firms must use to file offering documents and information pursuant to FINRA Rules 5122 (Private Placements of Securities Issued by Members) and 5123 (Private Placements of Securities) (Filer Form). The updated Filer Form, which became available in the FINRA Firm Gateway in May of [...]
Regulatory Notice 16-39: Trade Reporting and Compliance Engine (TRACE)
In 2001, the Securities and Exchange Commission approved the Trade Reporting and Compliance Engine (TRACE), a rule that requires all member firms to report secondary market transactions in eligible over-the-counter fixed income securities to FINRA. Unlike equities, over-the-counter securities trades are private transactions between counterparties and were not previously publicly [...]
Reminder: Testing ORF and ADF Changes for Trade Reporting and T+2 Settlement
In accordance with the industry-led initiative to shorten the settlement cycle from three business days (T+3) to two business days (T+2), FINRA continues to make testing available in the NASDAQ Testing Facility (NTF) for associated changes to equity trade reporting. The amended rule is designed to enhance efficiency, reduce risk, [...]
FINRA RULE 3130 (ANNUAL CERTIFICATION OF COMPLIANCE AND SUPERVISORY PROCESSES)
FINRA Rule 3130 (formerly known as NASD Rule 3013) requires the CEO to CERTIFY that the firm has a PROCESS to adopt adequate Supervisory Policies and Procedures. The goal of the Rule is to “promote regular and meaningful interaction between senior management and compliance personnel to ensure that compliance is given [...]