Blog
Notice to Members 06-23 & Your Firm’s Annual FINOP Review
Back in the early 2000’s, FINRA (then known as the NASD) came out with Notice to Members 06-23 (“Notice”). This Notice goes into detail about the responsibilities of the FINOP. Whether your FINOP is employed full-time in-house or is outsourced, the Notice applies. There are further considerations for the FINOP if the role is outsourced.
The Outsourced FINOP
Running a broker dealer is an expensive task these days – more regulations, hyper focus on transparency in the books and records, and studying all potential fraud risks within broker dealers. Cutting costs can seem like a daunting feat for anyone. One of the easiest ways to manage your broker [...]
Regulatory Notice 22-12 TRACE Amendments
FINRA Adopts Amendments to TRACE Reporting Rule to Require Identification of Portfolio Trades Effective May 15, 2023 if you trade in TRACE-eligible securities and those securities are part of a portfolio trade, you will be required to input an appropriate modifier. The Sale Condition 4 modifier, available via the TRAQS [...]
PTE and IRA Rollover Recommendation Considerations
U.S. Department of Labor’s ("DOL") recently published final prohibited transaction exemption regarding investment advice for IRA and ERISA plans (PTE 2020-02). This exemption became effective on February 16, 2021 allowing for a transition period to comply. Key elements include, written acknowledgments of fiduciary status by both the broker-dealer and the [...]
Regulatory Notice 22-18: Forgery and Falsification
Regulatory Notice 22-18 reminds firms of their rule obligation related to forgery and falsification of records and provides Firm’s with some specific examples that they have encountered from other Firms. These examples are great tools to review against your program and audit to ensure that your Firm is meeting rule [...]
Private Placement Best Practices from FINRA Disciplinary Actions
FINRA (Financial Industry Regulatory Authority) publishes a monthly review of disciplinary actions taken against both firms and individuals. These disciplinary actions are useful tools to look for trends in violations and other sanctions. These trends can assist you in identifying weak areas in your Firm’s compliance programs or surveillance. Below [...]