When a broker-dealer implements a significant change in the strategies and activities of the business, FINRA requires firms to file a continuing membership application (“CMA”) to modify its membership agreement. Through this requirement, FINRA seeks to help protect investors by ensuring that firms reflect these changes in their policies, procedures, and supervisory and compliance systems.
Failure to timely update information on an individual form U4 may lead to potential fines and suspensions for a registered person, especially if the act is willful. Examinations and sweeps performed by FINRA generally reveal exceptions.
Complete reliance on third-party outsourcing may negatively impact your compliance program. Other firms’ mistakes can serve as valuable cautionary tales to guide your decision-making process when establishing and maintaining relationships with third-party vendors.
FINRA Rule 3130 serves as an annual requirement to focus on the firm’s overall compliance programs through purposeful interaction between executive members and compliance officers. You might be wondering how firms ensure compliance with this rule. In this blog, we will address some frequently asked questions related to the annual certification requirement and the surrounding process.
MasterCompliance has been assisting clients with the purchase or sale of broker-dealers and the related FINRA application process since 2003. At times, clients will come to us with the need for a broker-dealer, and often, the best way to accomplish that goal is to buy an existing broker-dealer. There are many benefits to purchasing an existing broker-dealer. We have years of experience and vast expertise in putting these deals together to benefit all parties involved.
Since 2003, we have been assisting firms with starting new broker-dealers and the related registration process with the FINRA, SEC, and MSRB. Some of the types of broker-dealers that we have assisted in starting new firms include Investment Banking firms; Private Placement firms; Retail firms with clearing relationships; and Merger & Acquisition firms.
Last month, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert regarding examinations that will focus on broker-dealers’ compliance with Regulation Best Interest. The SEC wanted to make clear that the Regulation Best Interest compliance date of June 30, 2020 will not be extended. The OCIE will begin examinations with the program and will continue to add this element as part of exams for one year after the implementation date.
FINRA 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 is a list of a few key actions from last month.
Earlier this month, FINRA hosted a Small Firm Conference Call to discuss updates and implications of COVID-19 (Coronavirus). If you were not able to listen to the call live, a replay recording is available on demand. This recording provides and discusses many highlights noted in the FAQs Related to Coronavirus Pandemic.
Earlier this month, FINRA hosted a Small Firm Conference Call to discuss updates and implications of COVID-19 (Coronavirus). If you were not able to listen to the call live, a replay recording is available on demand. This recording provides and discusses many highlights noted in FINRA’s FAQs Related to Coronavirus Pandemic.