Are you thinking about changing the products your broker/dealer offers, adding additional representatives or branches, or changing the ownership structure of your firm?
Material changes to a broker dealer's business or ownership structure may require the firm to file an application for continuing membership (1017 application) with FINRA. These applications begin with a letter to determine materiality; which must be filed with your FINRA District Office. Once a decision is rendered, if the change is not material according to FINRA, the firm can make the changes required by updating its Form BD, supervisory procedures, etc. If the change is material, the firm must file a complete application for the change.
A 1017 application must address the same 14 standards as a new broker dealer application and can be time consuming and confusing. Information that may need to be included in the application consists of a business plan outlining the change and its impact on your business, financial projections on how a change in business, number of reps or new branches will effect your revenues, expenses and net capital, supervisory procedures, biographical information on new owners or supervisors, etc. The Broker Dealer Compliance team at Regulatory Compliance is experienced in both new broker dealer applications and broker dealer 1017 changes. Our experienced staff has performed numerous 1017 application requests in every FINRA District and has a clear understanding of what regulators are looking for so we can complete the process as quickly and efficiently as possible based on response from clients and regulators.
Let us help you work through this sometimes daunting 1017 process so you can concentrate on the more important matters at hand, running your business.
