The SDDco Client Update
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The National Futures Association (“NFA”) issued three recent notices to members regarding filing requirements: Notice I-15-09: Important notice to CPOs regarding changes to EasyFile for filing annual pool financial statements Notice I-15-05: Chief compliance officer report filing requirements for Swap Dealers and Major Swap Participants Notice I-15-08: Extension of deadline for FCM CCO Annual Reports
The PCAOB published the findings of the initial inspections of broker-dealer audits and attestation engagements under the new PCAOB standard to remind auditors to comply with the protocol. Many auditors will be applying these new requirements for broker-dealer clients with fiscal year-end December 31, 2014. The first five audit/attestation inspections observed auditor deficiencies. The requirement to follow
The CFTC Division of Swap Dealer and Intermediary Oversight issued no-action relief on January 23, 2015, to certain introducing brokers (“IBs”) regarding net capital requirements under Regulation 1.10 and regarding financial reporting requirements under Regulation 1.17. “Foreign-domiciled IBs may file audited and unaudited form 1-FR-IBs, as applicable, using local accounting principles in effect where the
FINRA’s BrokerCheck isn’t the only site facilitating research on the backgrounds and credentials of investment professionals. Other regulator sites are also providing tools to help investors research qualified advisers and firms, stay up-to-date on fraud protection, and link to investor education. In November of 2014, the Office of Consumer Outreach at the Commodity Futures Trading
The SEC, following a mandate by the Dodd-Frank Wall Street Reform and Consumer Protection Act, proposed a rule, which would require public companies to disclose their hedging policies for directors and employees. If enacted, certain companies must disclose, in proxy and information statements for the election of directors, whether they allow directors, officers, and other
In this month of February, FINRA and the SEC’s Office of Investor Education and Advocacy (“OIEA”) issued separate investor alerts on cybersecurity investor education. FINRA Alert: Cybersecurity and Your Brokerage Firm: Prompts investors to ask for firm’s cybersecurity policy Gives investors a list of questions to pose to better understand practices, activities, and policies Helps
FINRA’s Report on Cybersecurity Practices ~ Feb. 2015 (the “RCP”) details practices that firms can tailor to their business model as they strengthen their cybersecurity efforts. The RCP also covers the results of FINRA’s 2014 targeted examination (“sweep”) of a cross-section of firms, including the threats to firm data, weakness in systems, and the ways firms
When conducting exams in 2015, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) will heighten its focus on three hot spots concerning broker-dealers, investment advisers, and transfer agents: 1. Matters impacting retail investors saving for retirement 2. Issues related to market-wide risks 3. Illegal activities (identifying such using data analytics) 2015 OCIE FOCUS: Retail