RIA Branch Audit Planning

RIA Branch Audit Planning

Investment advisers should consider the need to perform a branch office inspection of branch offices pursuant to a branch office inspection schedule. Firms should consider whether a branch audit is warranted using factors such as nature and complexity of the branch’s business, volume of business, complaints, disclosures, number of registered persons, and other relevant factors determined by the firm. Firms are to document the exam schedules for each branch office including a description of the factors used to determine the exam cycle for such locations.

Various states require investment advisers to conduct regular inspections of their branch offices. For example, an investment adviser registered in Georgia is required to inspect each office location at least annually to ensure that its written policies and procedures are enforced. Even when an investment adviser is not explicitly required to conduct branch inspections, it should still implement a branch inspection program as part of its supervisory procedures. Also, investment advisers lacking an adequate branch office inspection program expose themselves to significant liability for failure to supervise in the event misconduct at the branch goes undetected.

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2019 FINRA Renewal Program

2019 FINRA Renewal Program for BDs and RIAs

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.

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IT’S ALMOST 2018!!!! As we approach the New Year, firms should make sure that they start off on a good note.  Below are the regulatory filings, request for comments, and certification due dates for the month of January. FINRA does not list any conferences or events for the month. JANUARY 2018 January 2nd Annual Audit Reports Due FCS Verification Period Begins January 3rd Short Interest Reporting Due January 12th Deadline for Comments on a Proposal to Amend Rule 3110 January 16th 4530 Customer Complaints Filings Due January 25th FOCUS Schedule 1 Filings Due FOCUS Part 2/2A-Quarterly Filings Due Form Custody Read more about FINRA’S COMPLIANCE CALENDAR – January 2018[…]


As November approaches, let’s take a look at the upcoming deadlines and educational opportunities that are on FINRA’s compliance calendar for the month.   Please note that the calendar does not include all regulatory and filing responsibilities for firms.  Therefore, you should check other resources to ensure that your firm does not miss any important deadlines. Read More…