Important Reminders

Contributed by: Laura Crosby-Brown

 

Annual Audit – The due date for annual audits are as follows:

Year-end Date                    
January 31, 2009                     
February 28, 2009                  
March 31, 2009             
        

Due Date
April 1, 2009
April 29, 2009
June 1, 2009


Remember - audit reports must be received by FINRA and SEC on or before the due date.  (Note – Don’t forget to send a report to any states in which you are registered that require filing by the due date.)

FOCUS FilingsFOCUS filing dates for the next three months are as follows:
           

If you file:
Monthly
Quarterly/Monthly 
Monthly
Period
February 2009
March 2009
April 2009
Due Date
March 24, 2009
April 24, 2009
May 26, 2009

Keep in mind that if your company’s year-end is February 28, 2009 or April 30, 2009 and you are normally a quarterly FOCUS filer, you have a Fifth FOCUS due on March 24 or May 26, respectively.

 MSRB G37/G38 Filings -  If you are a MSRB member and are required to file a G37 or G38 due to reportable Political Contributions, the filing due date is April 30, 2009 for the quarter ending March 31, 2009. Log onto www.msrb.org for more information.

3070 ReportingIf you have customer complaints that require reporting under Rule 3070 for the quarter ending March 31, 2009, these reports must be completed by April 15, 2009.

 New SIPC AssessmentSIPC has determined that the “fund” has fallen below $1B and will likely remain that way for at least 6 months. Therefore, effective April 1, 2009, a new assessment equaling ¼ of 1% of the firm’s net operating revenues will replace the $150 membership fee currently assessed. Firms must complete and file an assessment form. Firms with fiscal year-ends between April and October 2009 will be the first to be required to file this new assessment form. Firms with an April fiscal year-end will be required to file SIPC-7T (General Assessment Reconciliation Form) for the year ended 4/30/09. Revenues reported on the form will be for the one month period of April 1 through April 30, 2009. Firms with a year-end on December 31, 2008, January 31, 2009 February 28, 2009 or March 31, 2009 are not required to file the new assessment at this time as the effective date of the change occurred after their fiscal year-end. For more information, visit www.sipc.org.

Holidays

April 10 - The Markets and Regulatory Compliance will be closed on Good Friday

3012 Testing and Verification – You are required to test and verify your Supervisory Procedures and present a report to senior management within one year of the anniversary of your previous report. For firms that have a due date between now and April 1, 2009, now is the time to make certain you have documented any testing you have done during 2008 or the beginning of 2009..

3013 Certification – The senior business officer of each broker-dealer is required to sign the annual 3013 certification (required language found in IM-3013 or new FINRA Rule 3130) on or before the anniversary of his/her signature of the previous certification.
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