Form CRS Updates in 2020 (Part 1)

Form CRS Updates in 2020 (Part 1)

On October 8th, the SEC release another update to the FAQ for Form CRS, this time focusing on the Disciplinary History section. After so many updates, it is a good idea to go back through to refresh your memory.

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FINRA Report Filing

FINRA Report Filing Due Dates for 2021

FINRA recently released a notice about 2021 and first quarter of 2022 FINRA Report Filing Due Dates to assist members in their financial reporting obligations for Annual Report, Financial and Operational Combined Uniform Single (FOCUS), Form Custody, and supplemental FOCUS Report filings.

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Order Routing

Order Routing and The Price of Non-Disclosure

In May of this year, the SEC fined Bloomberg Tradebook LLC for $5 million, censured the firm, and issued a cease and desist order for misleading customers about how their orders were routed. Specifically, the SEC found that the Firm made material misrepresentations in regard to order routing. They omitted material facts about how they handled certain customer trade orders.

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FINRA Rule 3210

FINRA Rule 3210: Accounts At Other Financial Institutions

On April 3, 2017, FINRA Rule 3210 for Accounts At Other Broker-Dealers and Financial Institutions officially replaced NASD Rule 3050, Transactions for or by Associated Persons. In summary, FINRA Rule 3210 requires prior notification by an associated person to their member firm before they establish an account at another financial institution. Accounts include any securities transactions in which the Associated Person has a financial interest or with respect to which such person had discretionary authority. Read More…

Supervisory Control

Supervisory Control: The Basics of Rule 3120

Most broker-dealers are aware of their annual requirement to test and document their firm’s compliance program. But, the question remains if firms are meeting the full requirements of the rule. Below are the basics of the former NASD Rule 3012, now FINRA Rule 3120, for establishing and maintaining a system of supervisory control. Read More…


Supervision of Supervisory Personnel

FINRA Rule 3110 provides the requirements for building and maintaining a supervisory structure that is in compliance with rules and regulations. Among other requirements, this rule addresses the documentation and supervision of supervisory personnel in 3110(b)(6). What is FINRA Rule 3110(b)(6)? Rule 3110(b)(6) requires firms to document supervisory functions and responsibilities of each registered supervisory principal. It also establishes procedures to prohibit self-supervision and situations in which the supervisory principal reports to and/or has their compensation or continued employment determined by an individual or individuals that they are supervising. Lastly, it provides a carve-out for those who are unable to Read more about Supervision of Supervisory Personnel[…]