FINRA warns member firms to be on the lookout for a fraudulent phishing email that is currently circulating. Recently, member firms have reported to FINRA that they have received suspicious emails targeting their compliance personnel.Read More…
If you are an adviser to a private fund (i.e. hedge fund or pooled investment vehicle), do you know if you are deemed to have custody? If so, is your Form ADV Part I completed correctly?
Since there is a significant increase in compliance responsibilities for firms that have custody of client funds and/or securities, it’s critical that you consider whether or not your firm will be deemed to have custody.
Welcome to the third and final part in our series on the three main suitability obligations outlined in FINRA Rule 2111 (Suitability). As with our earlier posts, “FINRA Rule 2111: Reasonable-Basis Suitability” and “FINRA Rule 2111: Customer-Specific Suitability”, we will begin with a brief overview of the three main suitability obligations imposed on broker-dealers and their associated persons; then, this particular blog will focus in on Quantitative Suitability.
This post is the second in our three-part series on the three separate and distinct suitability obligations outlined in FINRA Rule 2111 (Suitability). As with our previous post, “FINRA Rule 2111: Reasonable-Basis Suitability”, we will begin with a brief overview of the three main suitability obligations imposed on broker-dealers and their registered representatives; then, this particular blog will focus in on Customer-Specific Suitability.
Although suitability is a well-established principle within the securities industry, broker-dealers and their registered representatives sometimes forget that FINRA Rule 2111 (Suitability) has three separate and distinct suitability obligations. We will begin with an overview of all three main suitability obligations. Then, we will be going in-depth on these areas across three different blogs; this particular blog will focus in on Reasonable-Basis Suitability.
In August 2018, the U.S. Securities and Exchange Commission (“SEC” or the “Commission”) adopted amendments to eliminate, integrate, update, or modify certain disclosure requirements that the Commission has deemed to have become duplicative, overlapping, or outdated in light of other SEC disclosure requirements, U.S. Generally Accepted Accounting Principles (“U.S. GAAP”), or changes in the information environment. The amendments are intended to aid the disclosure of information to investors and to simplify compliance without significantly altering the total mix of information provided to investors.
The 2019 FINRA Renewal Program for Broker-Dealers, Investment Adviser Firms, Investment Adviser Agents, Investment Adviser Representatives, and Branches is scheduled to begin on November 12, 2018.
Firms should note the following key dates in the renewal process:
- November 12, 2018 – Preliminary statements are available via the E-Bill section of WebCRD. Preliminary statements are not mailed to firms.
- December 17, 2018 – Full payment of Preliminary Statements is due.
- January 2, 2019 – Final Statements are available via the E-Bill section of WebCRD.
- January 21, 2019 – Full Payment of Final Statements is due.
In August 2018, the U.S. Securities and Exchange Commission (the “SEC”) announced that it has adopted amendments to Rule 15c2-12 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), in an effort to enhance transparency in the municipal securities market. The SEC has stated that the commission believes the amendments will provide[…]