The topic of FINRA controls testing requirements often comes up on the context of broker-dealer consulting, particularly because there is an annual testing requirement. FINRA has often provided guidance in this space and last week, …
Who Must be Fingerprinted at a FINRA Broker-Dealer?
The question of who must be fingerprinted at a FINRA dealer is one that often comes up in questions from clients. The answer can be found in SEC Rule 17f-2 – Fingerprinting of Securities Personnel. …
FINRA’s ‘5% Rule’ Regarding Markups
FINRA Rule 2121 governs markups in securities transactions. The rule requires that a FINRA member buy or sell a security at a price which is fair after taking into account all relevant circumstances, including market …
FINRA Rules for Handling Customer Checks
Most FINRA broker-dealers operate pursuant to an exemption from SEC Rule 15c3-3 (the Customer Protection Rule). This rule requires that broker-dealers choosing to receive or hold customer funds must compute the Reserve Formula on at …
FINRA BD Branch Offices in Executive Suites? Absolutely.
These days, it is not unusual for a registered representative of a brokerage firm, or any other small business owner for that matter, to conduct business from a virtual office or other part-time office. Many …
FINRA Anti-Money Laundering Independent Testing
It is the time of year when many broker-dealers are scheduling their annual independent test of their anti-money laundering programs. These tests are required by FINRA Rules. More specifically, FINRA Rule 3310 (formerly NASD Rule …
FINRA Compliance When Customers are Hunting for Yield
Today, December 1, 2014, a quick check of the web shows that the national average rate for a one year FDIC insured certificate of deposit is 0.27% APY. The rate on savings accounts is 0.09%. …
FINOP News – FINRA South Region Compliance Seminar
November 21, 2014 FINRA Financial and Operations Update The FINRA South Region Compliance Seminar was held on November 20 and 21, 2014 in Fort Lauderdale, Florida. During the session on Financial and Operational Issues …
SEC Rule 17a-4 – An Old Rule in a New World
Electronic Recordkeeping and FINRA Email Retention Requirements – SEC Rule 17a-4(f) The electronic recordkeeping requirements for broker-dealers are spelled out in SEC Rule 17a-4(f). SEC Rule 17a-4 is known as the broker-dealer record retention rule. …