1017 Material Change Determination

1017 Material Change Determination

When a member intends to add a line of business, FINRA has shown that this type of expansion is often a significant event that impacts the firm’s supervisory and compliance infrastructure, personnel, and finances. When such an impact occurs, FINRA staff is required to verify that the member continues to meet each of the membership criteria identified in Rule 1014. However, FINRA recognizes that any proposed new business line’s characterization as a “material change in business operations” ultimately depends on assessing all relevant facts and circumstances. Certain proposed new business lines, such as market-making, underwriting, and acting as a dealer Read more about 1017 Material Change Determination[…]

1017 Change in Membership

1017 Change in Membership

The Firm should review areas of its business to determine if any current or future changes to the Firm’s business may warrant a change in membership application (a.k.a. “CMA” or “1017”). FINRA requires firms to file a continuing membership application (CMA) whenever they seek to expand their operations activities, and for other business events, as indicated in NASD Rule 1017(a) (Continuance in Membership Application or CMA). Firms also must file an application whenever they seek to modify or remove restrictions previously imposed in a membership agreement (a membership agreement change). Failure to comply with this requirement may provide a basis Read more about 1017 Change in Membership[…]

Buying A Broker Dealer: Pros and Cons

Pros and Cons of Buying A Broker Dealer

Considerations for Buying a Broker Dealer

If you find yourself in need of a broker dealer, you have the option to either buy an existing one or start one from scratch. MasterCompliance has years of experience in both brokering broker dealer transactions as well as assisting our clients create new broker dealers, and in our experience buying a broker dealer tends to be the most popular choice. While the speed and convenience of buying a broker dealer are favorable, there are pros and cons to this option you should consider.

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nma process

The NMA Process – Start A New Broker-Dealer

In order to start a new broker-dealer, you must submit a new membership application (NMA) to the Financial Industry Regulatory Authority (FINRA).  The NMA process is often an arduous process.  To assist clients, we have a team of experts that can simplify the process, answer any questions, and get you to the finish line. Read More…

Buy or Start a Broker-Dealer: Weighing the Two Options

Are you looking to start a broker-dealer or buy a broker-dealer? If so, we can assist you in weighing the two options.  Securities Compliance Management, Inc., also doing business as MasterCompliance, is a full-service compliance consulting firm.  We have assisted many clients in starting and buying a broker-dealer.  There are many factors that you should consider before deciding which option is the best for you.   Read More…

FINRA Rule 3210 (Accounts at Other Broker-Dealers and Financial Institutions)

FINRA Rule 3210 (Accounts at Other Broker-Dealers and Financial Institutions), which replaces the previously used NASD Rule 3050, Incorporated NYSE Rules 407 and 407A and Incorporated NYSE Rule Interpretations 407/01 and 407/02, was approved by the SEC in April of 2016, and became effective in April 2017. This is a consolidated rule governing accounts opened or established by associated persons at firms other than the firm at which they are employed, ensuring that member companies, brokers, and advisors maintain ethical standards.  Read More…