Resources/ Updates - June 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.


Mutual Funds May Share Related Performance Info Conditionally

For the first time, sponsors of mutual funds may include the “Related Performance Information” of preceding, separately managed funds in sales literature sent to institutional investors and their financial intermediaries, such as broker-dealers and RIAs. The conditional change now in effect, was enabled by the May 12, 2015, FINRA interpretive response letter (the “Letter”) to

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Foreign Business Owners ~ Potential August Filing Extension of Form BE-10

10% owners of foreign businesses are subject to new reporting that was originally due by May 29 or June 30,  2015, as required. However, the extension deadline for all new filers has been amended.  If you need even more time to fulfill this reporting obligation, you might get it.  The Form BE-10 extension for filing form now provides

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How OCIE Evaluates Broker-Dealer AML Compliance

“We take AML very seriously,” said Kevin Goodman in his speech on June 18, 2015, to SIFMA conferees.  Kevin Goodman, National Associate Director of the Office of Compliance Inspections and Examinations (“OCIE”) Broker-Dealer Examination Program, stressed “the critical importance” of broker-dealers’ anti-money laundering programs and the heightened focus of AML compliance in SEC firm exams. 

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CFTC Extends Valuation Reporting Relief for Swap Dealers & MSPs

Once again, the Commodity Trading Futures Commission’s Division of Market Oversight (“CFTC Staff”) issued a one-year extension of the no-action relief within no-action letter 14-90.  The new expiration date is June 30, 2016.  Swap Dealers (“SDs”) and Major Swap Participants (“MSPs”) are relieved “from the obligation to report valuation data for cleared swaps as required

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Subscription-Way Securities Sales ~ Relief on Forwarding Customer Funds

Regarding broker-dealers “promptly” transmitting checks connected to subscription-way securities sales, FINRA has issued limited relief as follows to enable proper completion of suitability reviews: A broker-dealer (“firm”)  may hold a customer check payable to an issuer or an appropriate third-party payee acting obo the issuer (e.g., a transfer agent or custodian) for up to seven

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Broker-Dealer Continuing Ed Update

On June 17, 2015, FINRA posted its final in a trio of podcasts related to the latest regulatory advisory on Firm Element continuing education (“CE”) training for broker-dealers. These podcasts reinforce the CE Council (“CEC”) Spring Firm Element Advisory 2015–a semi-annual report that identifies and links to current regulatory and sales practice topics suggested for possible inclusion in broker-dealers’ Firm Element training

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Background Checking Burden is Imminent for Broker-Dealers

At year-end, 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 a Form U4. The implementation date is just weeks away, July 1, 2015. Rule Compliance As with any rule change, it is not possible to predict how FINRA will

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CFTC Registration Relief Concerning International Financial Institutions

On June 5, 2015, the Commodity Futures Trading Commission (“CFTC”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) announced it will not recommend CFTC action for “failure to register as an introducing broker (“IB”) or commodity trading advisor (“CTA”) against persons located outside the U.S. that facilitate swap transactions for International Financial Institutions (“IFIs”) that

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NYC Commercial Rent Tax is Due

NYC Commercial Rent Tax (“CRT”) (and any applicable payment) is due June 22, 2015. CRT is paid by tenants who: Occupy or use a property in Manhattan, south of 96th Street for any trade, business, profession, or commercial activity, and Pay an annual or annualized gross rent paid of at least $250,000; and Meet no exemptions (short rental

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FINRA Swaps Comp Disclosure for Education when Registered Reps Trade Firms

Last year FINRA proposed and then withdrew a new rule requiring a hiring broker-dealer to make certain compensation-related disclosures to the former customers of a registered representative transferring their assets to the new firm.  Now FINRA seeks feedback by July 13, 2015, on a new rule that would require the hiring or “recruiting member firm”

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FINRA Limits BrokerCheck Link Requirement to Retail Sites

FINRA has revamped its former proposal regarding mandatory BrokerCheck links on broker-dealer web sites and filed with the SEC. The new proposal, if approved, would limit the link requirement to FINRA members servicing retail investors.  Approximately 2,675 broker-dealers (“members”) would be required to reference and hyperlink to BrokerCheck on their homepage and on any site

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SEC Looks to “Modernize” Reporting for Investment Advisers

Modernization for investment advisers may mean more reporting on new forms and enabling shareholder reports sent though websites.  On May 20, 2015, the SEC proposed new rules, forms, and amendments to update to the reporting and disclosure of information by registered investment companies (“RICs”) and registered investment advisers (“RIAs”).  The goal is to “improve the quality and accessibility

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New Q&As on Broker-Dealer Advertising Rules

FINRA published additional questions and answers on their Advertising Regulation page to augment earlier guidance on rules governing communications with the public. The new questions tackle: Non-Promotional Communications Social Media Posts in Online Interactive Electronic Forums Filing Exclusion for Non-Material Changes to Previously Filed Retail Communications Article Reprints Institutional Communications Rule 482 Issues Disclosure of

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in two industries.

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