Resources/ Updates - January 2015

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 sddco.com website. Always check with your accountant and/or attorney.

Jan27

FINRA’s Exam Priorities 2015 Part I: Recurring Challenges

To support investor protection and market integrity, FINRA published its annual regulatory and examination priorities letter.  Significant concerns going forward include risky business operations, some old and a few new. RECURRING CHALLENGES Over the years, FINRA has observed that challenges in five areas contribute to firms and registered representatives at times compromising the quality of

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Jan27

FINRA’s Exam Priorities 2015 Part II: Sales Practice

To support investor protection and market integrity, FINRA published its annual regulatory and examination priorities letter.  Significant concerns going forward include risky business operations, some old and a few new. SALES PRACTICE Products FINRA is concerned with certain products as well as sales and distribution practices.  Some complex products may be subject to substantial market, credit, liquidity

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Jan27

FINRA’s Exam Priorities 2015 Part III: Financial and Operational Priorities & Market Integrity

To support investor protection and market integrity, FINRA published its annual regulatory and examination priorities letter.  Significant concerns going forward include risky business operations, some old and a few new.   FINANCIAL AND OPERATIONAL  PRIORITIES Funding and Liquidity: Valuing Non-High-Quality Liquid Assets At times, firms’ funding and liquidity plans rely on being able to sell or

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Jan13

NFA Compliance Standard Now Covers Swaps Business

December 1, 2014, the Commodity Futures Trading Commission (“CFTC”) approved a logical, amendment to NFA Compliance Rule 2-4, effective January 5, 2015, to also cover swaps-related activities. Rule 2-4, Just and Equitable Principles of Trade, “sets forth the basic ethical standards requirement that Members and Associates observe high standards of commercial honor and just and

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Jan13

Annual FINRA & MSRB Verifications

Did you remember to fulfull these annual FINRA & MSRB obligations for 2015? FCS Annual Certification Deadline ~ January 27, 2015: All FINRA member firms must complete a review of info maintained in the FCS (FINRA Contact System). See FCS review guide here. See Contact Info Notice 07-42 here. SAA Annual Certification Period ~ January

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Jan13

Annual Audited Reports Go to SIPC Too

In July of 2013, the SEC approved many final changes to SEA Rule 17a-5 impacting broker-dealer reporting. Two changes impact annual reporting to the Securities Investor Protection Corporation (“SIPC”). One amendment requires that broker-dealer members of SIPC file their annual audited reports with SIPC (email SIPCAuditReports@sipc.org) in addition to filing them with the SEC and FINRA.

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Jan12

New York Eliminates Annual Wage Notification Requirement

New York employers will no longer be required to request employees annually acknowledge their wage. On December 29, 2014, Governor Cuomo signed a bill which removes the requirement mandating that employers notify and receive written acknowledgement from every worker about their rate of pay, allowances, pay day, etc. before February 1st of each year. The

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Jan09

SEC Accelerates Approval of Broker-Dealers Background Checking Registrants

The SEC approved FINRA’s proposal to require broker-dealers to perform public record background checks on their FINRA registration applicants within 30 days of filing.  The implementation date is July 1, 2015. Backfill  On September 18, 2014 FINRA filed a rule change to adopt NASD Rule 3010(e) (Responsibility of Member to Investigate Applicants for Registration) as FINRA Rule

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Jan08

MSRB’s EMMA Now Accepting New Asset-Backed Securities Disclosures

The MSRB has amended EMMA, its Electronic Municipal Market Access service, to accept and disseminate newly required disclosures related to municipal asset-backed securities (municipal ABS as of January 9, 2015.  Pursuant to Section 943 of the Dodd-Frank Act, the SEC adopted new rules related to representations and warranties. One of these rules, Rule 15Ga-1, requires

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Jan08

BDs and IAs Should Reconcile Final Renewal Statements

FINRA issued Final Renewal Statements and reports for registered entities (broker-dealers, investment adviser firms, agents and investment adviser representatives, and branches). Firms should review, reconcile, and respond to their Final Renewal Statements as well as view the reports available as of January 2, 2015, on Web CRD/IARD. These statements reflect the final status of broker-dealer,

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Jan07

SDDCO 2014 Tax Filing Tables

Use these quick reference, 2014 Tax Rate Tables when planning and preparing returns this upcoming tax season. [From Revenue Procedures 2013-35] So far, opening day of the 2014 filing season is set for Tuesday, January 20, 2015. The IRS advises using the e-file method. Clients should contact the SDDCO tax department for assistance at 212-751-4422; info@sddco.com; Tax Partner, Philip

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Jan07

Tax Benefit Extenders for 2014

With the better-late-than-never passage of tax extender legislation on December 19, 2014, the IRS announced it anticipates opening the 2015 filing season on Jan. 20, 2015. This confirmation follows Congress renewing through the end of 2014, many “extender” provisions of U.S. tax law that had expired at the end of 2013. On December 16, 2014,

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Jan06

Businesses Get Set for 1099 Reporting

It’s time for businesses to gear up for 1099 reporting to the Internal Revenue Service (IRS).  Form 1099 is a group of informational IRS returns used to report the income that individuals receive aside from compensation paid by an employer.  While wages, salaries, and tips are reported on Form W-2, Form 1099 reports self-employment income, awards, dividends,

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Jan02

FOCUS Report 2015 Deadlines for Broker-Dealers

FINRA detailed the 2015 deadlines for broker-dealer firms to file their FOCUS reports. To comply with SEC Rule 17a-5, FINRA member firms must send monthly, quarterly, and annual reports by the listed due dates. FOCUS filings are due within 17 business days of the end of each quarter Filing is done via the eFOCUS system,

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Jan02

Schedule of SSOI 2015 Filings for Broker-Dealers

FINRA issued the cutoff dates of Schedule for Supplemental Statement of Income (SSOI) filings for 2015. Regulatory Notice 12-11 requires broker-dealers to file, quarterly, additional financial or operational schedules or reports pursuant to Rule 4524. SSOI filings are due within 20 business days of the end of each quarter. For more information including the forms,

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Jan02

Form Custody Filing Schedule 2015 for Broker-Dealers

All broker-dealers must now file Form Custody with their Designated Enforcement Agency, at the same time as their quarterly FOCUS Reports. The 1st Form Custody filing is due January 27, 2015 File using FINRA’s eFOCUS system available on Firm Gateway Find Form Custody displayed as “Report Type” Custody along with FOCUS and Schedule I For

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Jan02

OBS Filing 2015 Due Dates for Carrying and Clearing Firms

FINRA Rule 4524 requires carrying or clearing firms to file, quarterly, a supplemental schedule for derivatives and other off-balance sheet items (OBS). This form provides info on their off-balance sheet assets, liabilities and other commitments. (For more on Rule 4524 and Regulatory Notice 13-10, see SDDCO Post: New Supplemental FOCUS Info Requirement.) File the OBS

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Jan02

Audited Report Due Dates for Broker-Dealers 2015

FINRA reminded firms of their filing due dates for the Annual Audited Report. Securities Exchange Act (“SEA”) Rule 17a-5(d) requires every broker or dealer registered pursuant to Section 15 of the SEA to file an annual audited report. A completed SEC Form X-17A-5 Part III must accompany a firm’s annual audit report. An extension may

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