Resources/ Updates - April 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 website. Always check with your accountant and/or attorney.


Does Top Dog Pay Fit Firm Performance? SEC Props New Comp Disclosure Rules

Yesterday, per a Dodd Frank Act mandate, the SEC voted 3-2 to propose rules to require that publicly traded companies disclose the relationship between their executive compensation and their firm’s financial performance.  These rules aim to up transparency and help shareholders make more informed decisions when voting to elect directors and when judging the compensation

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DOL Redefines Fiduciary ~ Amendment Proposed for Retirement Plan Brokers & Advisers

After a lifespan of hard work, the average American cherishes few things more than a tranquil and secure retirement.   In this spirit, the U.S. Department of Labor (“DOL”) proposed a new rule that would impose a client-first fiduciary standard to anyone compensated for providing retirement advice that is individualizes or specifically directed to a  plan

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SEC Asked to Approve Municipal Advisor Conduct Rule

The MSRB filed with the SEC their standard of conduct rule for municipal advisors on April 15th, taking another step towards barring unqualified individuals from advising state and local governments.  “MSRB Rule G-42 would establish core standards of conduct for municipal advisors (“MAs”), provide guidance on the obligations and prohibitions that accompany their federal fiduciary

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Revived Focus on Mutual Fund 12b-1 Fees

Consumer advocate groups collectively urged the SEC to update certain policies to better regulate investment professionals and products. In a letter to SEC Commissioner Mary Jo White, dated March 10, 2015, the Consumer Federation of America, Fund Democracy, AFL-CIO, Americans for Financial Reform, and other groups (“the consortium”) wrote, “The Commission can no longer afford

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CFTC Advisory on Ownership and Control E-Reporting and Deadlines

In an advisory to Reporting Parties on ownership and control reporting (“OCR”), commodity market participants are reminded to retrieve the necessary data from their customers and counterparties to submit new forms online and on time.  Filing dates begin September 30, 2015. The advisory from the CFTC’s Division of Market Oversight (“DMO”) and Division of Swap

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It’s Raining Investor Ed at the SEC

The SEC’s Office of Investor Education and Advocacy has been busy issuing the following alert and bulletins this spring: April 3, 2015 Updated Investor Alert: Beware of Companies Using the SEC Seal The updated Investor Alert helps investors identify fraud via unauthorized use of the SEC seal. March 31, 2015 Investor Bulletin: Bankruptcy for a Public

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MSRB Wants More Transparency: Proposed Changes to G-14 & RTRS Published

In the interest of market transparency and investor protection, the Municipal Securities Rulemaking Board (“MSRB”)  filed a proposed rule change, now published in the Federal Register, to amend the Real-Time Transaction Reporting System (“RTRS”), Rule G-14 RTRS Procedures, and subscription service (“proposed rule change”) with an effective date no later than May 23, 2016. Rule G-14 on

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SEC Seeks Feedback: Amend FINRA Membership Exemption for HFT Broker-Dealers?

On March 25, 2015, the SEC officially proposed that broker-dealers (“BDs”) trading in an off-exchange venue be required to become members of a national securities association, i.e.  FINRA, the Financial Industry Regulatory Authority.  Amendments to SEA Rule 15b9-1 would heighten the transparency and examination of such firms, many of which are engaged in high-frequency trading

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Startups & Tax Estimates

Startups should know their basic tax responsibilities on the Federal and state level from the get go.  Generally, an owner must calculate and submit to the IRS an estimated tax payment on a quarterly basis. This contrasts with salaried individuals who receive paychecks from an employer whereby the taxes have been withheld on perhaps a weekly or semi-monthly basis.

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Quick Tips on Estimated Taxes

Unsure if you need to pay estimated tax, where to pay, or even what it is?  Here is quick guide to help you figure it out. Who Needs to Pay? Anyone who doesn’t have taxes withheld (or enough tax withheld) from their paychecks and expects to owe over $1,000 in their federal tax return, must

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On Broker-Dealer Comp to Unregistered Peeps

FINRA Regulatory Notice 15-07 informs broker-dealer FINRA members (“members”) of the expanded governance regarding payments to unregistered persons for securities-related and capital-raising activities.  The Notice alerts members to the SEC approval to adopt these new FINRA rules and amendments effective August 24, 2015: FINRA Consolidated Rule 2040 (Payments to Unregistered Persons) FINRA Rule 8311 amended

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FINRA Pens Guidance on High-Frequency Trading

FINRA continues its charge to ensure the responsible practices of high-frequency trading (“HFT”) strategies.  On the heels of proposing rules that would require developers of HFT algorithms to register with the regulatory agency, FINRA released guidance on effective management and control practices for firms that use these strategies. Background In recent years, the use of

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Are the Rules for FINRA Broker-Dealer Membership Working?

In Regulatory Notice 15-10, FINRA is conducting a retrospective review of the membership application rules or “MAP rules” to assess their effectiveness and efficiency. Toward the primary goal of investor protection, the MAP Rules enable FINRA to evaluate the proposed business activities of new broker-dealer applicants as well as existing member firms seeking to change

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BD Risk Assessment Requirements: Spotlight Form 17-H

Form 17-H, the Risk Assessment Report for Broker-Dealers, was established as a Securities and Exchange Commission (“SEC”) filing at a time when the school of hard knocks reminded  us that the financial difficulties of an unregulated entity can take down an associated regulated entity. Case in point, in 1990, Drexel Burnham and Lambert Group, Inc.

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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