Renewals - The annual renewal process for broker-dealer and investment advisors began again in November. Some important dates in the calendar are as follows:
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WebCRD and IARD are unavailable
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January 4 |
Final renewal statements are available on CRD/IARD |
February 5 |
Full payment of any balance due shown on final renewal statements is due |
Regulatory Compliance will be providing copies of final renewal statements and payment reminders to our Compliance Partner and FINOP clients.
Annual Audit –The due date by which annual audit reports must be received by FINRA and the SEC are as follows:
Year-end Date
November 30, 2009
December 31, 2009
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Due Date
January 29, 2010
March 1, 2010 |
Note – Don’t forget to send a report to any states in which you are registered that require filing by the due date.
Auditors - All audits for broker-dealers need to be completed by a PCAOB member auditor. You can verify whether or not your auditor is a member by visiting www.pcaob.org. If your auditor is not a member, you will need to engage a new auditor to perform your audit for this and future years and will need to file a change of auditor notification through FINRA’s electronic notification system.
SIPC Assessment - Effective April 1, 2009, SIPC changed its assessment and required payment procedures. Broker-dealers are now required to pay an assessment equal to 1/4 of 1% of their annual net operating revenues, assessed semi-annually.
Firms that have a fiscal year end of April 30, 2009 or after need to complete the SIPC-7T Transitional Assessment Reconciliation. The form will be mailed to the firm by SIPC at the end of the firm’s year-end. It must be complete and returned to SIPC with the applicable payment within 60 days of the end of the firm’s fiscal year.
Note - A Supplemental SIPC Report must be included with your annual audit that is submitted to FINRA and the SEC.
Focus Filings – Focus filing dates for the next three months are as follows:
If you file:
Monthly/Quarterly
Monthly
Monthly |
Period
December 2009
January 2010
February 2010 |
Due Date
January 27, 2010
February 24, 2010
March 23, 2010 |
Keep in mind that if your company’s year–end is January 31, 2010 or February 28, 2010 and you are usually a quarterly FOCUS filer, you have a Fifth FOCUS due on February 24 or March 23, respectively.
MSRB G37/G38 Filings - If you are a MSRB member and are required to file a G37 or G38 to report political contributions, the filing due date is February 1, 2010 for the quarter ending December 31, 2009. Log onto www.msrb.org for more information.
3070 Reporting – If you have customer complaints that require reporting under Rule 3070 for the quarter ending December 31, 2009, these reports must be completed by January 15, 2010.
Contact Information – All FINRA member firms are required to review and confirm the contact information in the FINRA Contact System on or before Janaury 27, 2010.
In addition, MSRB member firm must review their G-40 Contacts and make any changes on or before Janaury 27, 2010.
Holidays –
December 31 |
The stock markets are scheduled to close at 1pm
Bond markets are scheduled to close at 2pm |
January 1 |
Stock and bond markets and Regulatory Compliance will be closed for New Years Day
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January 18 |
Stock and bond markets and Regulatory Compliance will be closed for Martin Luther King/Civil Rights Day
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February 15 |
Stock and bond markets and Regulatory Compliance will be closed for
President’s Day
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3012 Testing & 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 firm’s that have a due date between now and April 1, 2010, now is the time to start planning for this and to document any testing you have done during 2009.
3130 Certification – The senior business officer of each broker/dealer is required to sign the annual CEO certification (required language found in FINRA Rule 3130) on or before the anniversary of his/her signature of the previous certification.
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