On the Radar
Broker - Dealers
- During your cycle examination, FINRA will review the growth of your firm’s personnel, offices, and markets made over a 12- month period to ensure that the firm has not expanded beyond the restrictions set forth in your FINRA Membership Agreement. If there are no restrictions listed in your Membership Agreement, then your firm may operate under FINRA’s safe harbor for business expansion. Expansions in each area are measured on a rolling 12-month basis. You must keep current records of increases to personnel, offices, and markets, and review these numbers on a monthly basis to determine if a 1017 application, or Continuing Membership Application (“CMA”), should be filed. More
- Social networking websites such as Twitter, LinkedIn and Facebook have become increasingly popular among organizations large and small as a way to expand their business. We are seeing the SEC, FINRA and the NFA looking more closely at this form of communication. Regulators feel that these on-line communities provide opportunities for people to spread rumors and misrepresentations. Your firm is obligated to monitor the firm's communications through these sites to ensure compliance with current rules and regulations. More
Investment Advisers
- Effective 12 March 2010: Don’t be taken into custody because of the SEC’s recent amendments to Rule 206(4)-2, the “Custody Rule.” These new amendments are designed to provide additional safeguards when an IA has custody of client funds or securities by requiring the IA, among other things:
• annual surprise exam;
• qualified custodian send account statements directly ; and
• in certain cases gather a report of the internal controls relating to the custody of those assets from an independent public accountant subject to inspection by the PCAOB. More
- Social networking websites such as Twitter, LinkedIn and Facebook have become increasingly popular among organizations large and small as a way to expand their business. We are seeing the SEC, FINRA and the NFA looking more closely at this form of communication. Regulators feel that these on-line communities provide opportunities for people to spread rumors and misrepresentations. Your firm is obligated to monitor the firm's communications through these sites to ensure compliance with current rules and regulations. More
Broker - Dealers/Investment Advisers
- Social networking websites such as Twitter, LinkedIn and Facebook have become increasingly popular among organizations large and small as a way to expand their business. We are seeing the SEC, FINRA and the NFA looking more closely at this form of communication. Regulators feel that these on-line communities provide opportunities for people to spread rumors and misrepresentations. Your firm is obligated to monitor the firm's communications through these sites to ensure compliance with current rules and regulations.More