Resources/ Updates - November 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.


SEC Proposes New Public Disclosure Rule for Alternative Trading Systems

On November 18th, the SEC announced a proposed rule to add transparency and regulatory oversight of alternative trading systems (ATSs).  This rule will focus on ATSs’ off-exchange equity deals sometimes called “dark pools.” The proposed rule would mandate firms using ATS to file detailed disclosures about business activities that may present conflicts of interest between

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FASB Lease Accounting Standards Proceed ~ Could Tally $2 Trillion

The Financial Accounting Standards Board (“FASB”), the rulemaking board for U.S. accounting, voted to proceed with a new accounting standard that would require companies and other organizations to include lease obligations on their balance sheets. Standards Timeline The final Accounting Standards Update (“ASU”) is expected to be published in early 2016; however, the standard will

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Cybersecurity Webinar for Small Broker-Dealers

FINRA’s free one-hour webinar  for small firms addresses “building an effective cybersecurity program with limited resources.” Tune in for best data protection practices and ways to apply the National Institute of Standards and Technology (“NIST”) framework. Topics Covered Overview of NIST Framework Role of compliance in addressing cyber risks Factors for developing a cybersecurity program Focus

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Which FINRA Firms Get the Disaster Recovery Test?

FINRA has adopted new Rule 4380, which grants FINRA authority to designate firms to participate in FINRA’s business continuity and disaster recovery testing under Regulation Systems Compliance and Integrity (“SCI”).  The rule becomes effective on November 30, 2015.  The tests will be conducted once per year. Background on New Rule 4380 On November 19, 2014,

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FINRA Requirement Roundup ~ with Effective Dates

  FINRA to Require Electronic Submission of Subordination Approval Requests FINRA is launching a new electronic platform on Firm Gateway for firms to submit all new requests for approval of proposed subordinated loan agreements and secured demand note agreements (referred to as subordinations), including renewals of existing agreements.   FINRA will no longer accept new requests

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Reminder: Public Accountant Independence Statement Due ~ Dec 10th

In 2013, the SEC added a requirement for broker-dealers to identify their independent public accountant.  Pursuant to amended paragraph (f)(2) of SEA Rule 17a-5, broker-dealers must file a statement with the SEC and FINRA regarding this information.  The deadline for the yearly filing is December 10th. If the broker-dealer filed a “Statement Regarding Independent Public

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NFA Members ~ Cybersecurity Programs a Must as of March 2016

By March, NFA member firms will have to draft and enforce written policies and procedures to secure their customer data and access to their electronic systems. Backfill The CFTC recently approved the NFA’s Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 entitled Information Systems Security Programs.  The “Cybersecurity Notice,” covering all NFA membership categories—futures commission

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RIA Third-Party Exams ~ and Other SEC Maybes

New rulemaking governing investment adviser examinations is advancing on the mission list of the Securities and Exchange Commission (“SEC”). According to David Grim, Director of the SEC’s Division of Investment Management, in addition to Form ADV changes the “Division” is working on an initiative concerning potential rulemaking for the third-party compliance reviews of registered investment

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More on Crowdfunding Portals ~ Forms and Fees Proposed

The SEC has now adopted final regulations on crowdfunding, mandated by the JOBS Act Title III, enabling retail investors to buy within limits unregistered securities online. To offer these unregistered securities, private companies eligible for the crowdfunding exemption must use an intermediary—specifically an SEC registered broker-dealer or a new category: an SEC registered  ”funding portal.”

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Crowdfunding of Securities Made Possible ~ SEC Adopts Title III Final Rules

In a landmark decision, on October 30, 2015, the SEC adopted final equity crowdfunding rules, mandated by Title III of the JOBS Act, giving smaller firms a big boost in their ability to raise funding through the sale of securities online. Till now, securities investments could not be gotten from the average Joe…rather limited to

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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


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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