Resources/ Updates - March 2014

The SDDco Client Update

The SDDco Client Update is an action oriented email prepared in-house, tailored to client needs, and sent as an adjunct to our online newsletter.  Verified newsletter subscribers receive our Client Update once each month.

The SDDco Client Update is intended to provide general information only. It is not intended as, and should not be taken as, financial, tax, accounting, legal, consulting or any other type of advice specific to you or your firm. Users of the SDDco Client Update should not act or refrain from acting on the basis of information provided on the website. Always check with your accountant and/or attorney.


No Action Conditions for Broker-Dealers with Exemption Requests under Rule 15c3-3

A recent SEC no-action letter offers temporary relief to broker-dealers that have requested a temporary exemption under  the amended Customer Protection Rule 15c3-3. Customer Protection Rule 15c3-3(e) Amendments adopted under Rule 15c3-3(e) of the Securities Exchange Act of 1934, effective October 21, 2013, in part require the following: New Account Setup: “Carrying broker dealers” (those holding proprietary accounts for

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CFTC Advisory ~ Ways to Comply with Customer Information Safeguards

The Commodity Futures Trading Commission (CFTC) staff members have laid out data security practices for its regulated entities.  This guidance will help firms comply with industry regulations that protect customer financial information. Advisory 14-21 effects futures commission merchants( FCMs), commodity trading advisers (CTAs), commodity pool operators (CPOs) , introducing brokers (IBs), retail foreign exchange dealers (RFEDs), swap

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Multi-Manager Funds ~ When You Need Aggregate Fees Approved

Mutual funds often operate as multi-manager funds—where a fund’s primary adviser oversees  sub-advisers acting as the day-to-day portfolio managers. The Investment Management Division of the Securities and Exchange Commission (IMD Staff) issued guidance for multi-manager funds regarding if and when to get shareholder approval for aggregate rate changes. Main Message Multi-manager structures generally do not need to

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Will Limited Corporate Financing Brokers Get Lighter Rules?

FINRA is working towards trimming and reshaping governance to better fit the activities of limited broker-dealer categories. Last week, FINRA issued Regulatory Notice 14-09 seeking feedback on a proposed set of rules for the “limited corporate financing broker” (LCFB).  While an LCFB would be subject to the FINRA By-Laws and core FINRA rules, other rules

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FATCA Compliance Update

The Foreign Account Tax Compliance Act of 2010 (FATCA), targeting non-compliance by taxpayers with foreign accounts, requires online registration and the reporting of foreign financial assets. Per IRS Issue 2014-5, the revised final FATCA regulations are posted to the Federal Register.  Also, FATCA forms and instructions for 2014 are now available at, including the following: • Form

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On Best Execution for Municipal Dealers

The Municipal Securities Rulemaking Board (MSRB) invites comment on a proposal to establish—for the very first time—explicit best-executions standards for municipal securities dealers. The best-execution proposal supports MSRB market transparency plans started in 2012. Draft G-18 Draft Rule G-18: Execution of Transactions (“Draft G-18”) would require brokers, dealers, and municipal securities dealers (“dealers”) to use

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SDDco specializes
in two industries.

Our know-how and our network supports the financial services & tech industries.

We hold the right training and licensures to keep you in step and mitigate risk.

Our Credentials


SDDco supports
industry leaders.

We oversee back office functions so you can focus on your own clients.

Major banks, private funds, RIAs, BDs, and tech startups choose us.

Our Clients


SDDco is as good
as its great people.

Our CPAs, FinOps and
consultants are licensed,
experienced professionals.

Partner with us for start-ups and for ongoing accounting, compliance and tax work.

Our People


SDDco performs
services onsite.

Outsourced support with
SDDco isn’t out of sight.

We work in your space and for your team on a regular basis. Engage the expertise without the fulltime hire.

Our Praises


SDDco observes
AICPA principles.

Our inaugural firm began
when two CPAs opened
a NYC office back in 1952.

We faithfully maintain the CPA standards: integrity, competency, confidentiality….

Our Group