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FINRA recently filed proposed new regulations regarding broker-dealer compliance with the SEC to: (1) amend FINRA Rule 4512 (Customer Account Information) to require member firms to make reasonable efforts to obtain the name of and contact information for a trusted contact person for a customer’s account; and (2) adopt new FINRA Rule 2165 (Financial Exploitation of Specified Adults) to permit FINRA registered broker-dealers to place temporary holds on disbursements of funds or securities from the accounts of specified customers where there is a reasonable belief of financial exploitation of these customers. According to FINRA’s filing with the SEC, financial exploitation Read More....
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[Continued from FINRA Membership Interview – Part I] What happens during the FINRA Membership Interview? During the FINRA Membership Interview, the participants will discuss substantially all of the aspects of the firm’s proposed business. Emphasis will be placed on the FINRA, SEC, or MSRB rules applicable to the firm’s intended business, as well as the firm’s supervisory structure, the background and experience of the firm’s principals and representatives, and plans for future direction and expansion. Questions about how the firm will process transactions and how it will supervise activities to maintain FINRA compliance, among other things, must be answered by Read More....
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So, you’ve decided to start or own a broker-dealer. You have completed Form NMA, submitted it to FINRA Gateway via the New Membership Application process with all of your supporting documents, and have gone through a round or 2 of information requests with the FINRA Membership Application Program Group (the “MAP Group”). Now, you have just received a request to sit down with FINRA for the Membership Interview. So what do you do? The FINRA Membership Interview is one of the most critical steps in the FINRA New Member Application (NMA) (or Continuing Membership Application (CMA)) process. The interview, which Read More....
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FINRA has expanded its alternative trading system (ATS) transparency initiative. Beginning October 3, FINRA is now publishing monthly information on block-size trades occurring on ATS’s. Among other things, this data may be used by broker-dealers for market regulation surveillance purposes. The information can be found on FINRA’s website and is available free of charge. Through new technology, FINRA was able to begin publishing volume and trade count information for equity securities executed on ATS’s in June 2014. Then, in April 2016, FINRA began posting the remaining, non-ATS over-the-counter (OTC) equity volume by FINRA member broker-dealer and security. Publishing monthly ATS Read More....
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In June 2016, the Municipal Securities Rulemaking Board (MSRB) filed a proposed rule change with the Securities Exchange Commission (SEC) to revise the content outline for the Municipal Advisor Representative Qualification Examination (Series 50 exam). The content outline for the Series 50 exam has been amended to reflect changes to the laws, rules and regulations covered by the examination. These amendments also, among other things, incorporate the functions and associated tasks performed by a municipal advisor representative. MSRB Rule G-3(d) defines a municipal advisor representative as a natural person associated with a municipal advisor who engages in municipal advisory activities Read More....
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What do you do when you add a new product to your firm’s approved offering listing? How do your reps know that a new product has been added? Do your policies & procedures even address new products? What sort of training do you provide? Does your firm need to file a Continuing Membership Application (Form CMA)? As a compliance specialist for FINRA-registered broker-dealers, we encounter these type of questions from our clients on a regular basis, including FINRA, SEC, and MSRB compliance veterans. New Product Policies and Procedures FINRA urges firms to take a proactive approach to reviewing and improving Read More....
