Resources/ Updates - January 2016

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.

Jan31

Crowdfunding Notice & Filing Musts for the Broker-Dealer Intermediary

A new FINRA notice provides guidance on the notifications required of registered broker-dealers (“BDs” or “members”) related to crowdfunding activity under new FINRA Rule 4518 (Notification to FINRA in Connection with the JOBS Act). This info is essential for members who might act as intermediaries in offering or selling securities as permitted under SEC Regulation

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Jan28

Mutual Funds ~ Are Your Sub-Accounting Fees in Line with Rule 12b-1

In January 2016, the staff of the Division of Investment Management (“IM Staff”) shared its views in a guidance update entitled: Mutual Fund Distribution and Sub-Accounting Fees. The IM Guidance IM Staff covered issues related to registered mutual funds making payments to financial intermediaries that provide both shareholder and recordkeeping services for investors having shares

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Jan21

SEC 2016 Examination Hot Spots

This year, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) will continue to focus on the major areas it stressed in 2015.  The three hot spots concerning broker-dealers (“BDs”), registered investment advisers (“RIAs”), and transfer agents remain: Matters impacting retail investors saving for retirement Issues related to market-wide risks Illegal activities (identifying such using

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Jan13

SDDCO 2015 Tax Rate Tables ~ Filing Season 2016

During the 2016 Tax Season upon us, you or your tax professional will prepare and file your tax return for the 2015 tax year.  Use the handy 2015 Tax Rate Tables below [from Revenue Procedures 2014-61] when planning and preparing returns. Tax Season Dates Opening day of filing season 2015 is set for Tuesday, January 19, 2016. Deadline day to

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Jan12

2016 Holiday Recs from SIFMA ~ for Financial Markets Participants

The Securities Industry and Financial Markets Association (SIFMA) recommended a  2016 holiday schedule for financial markets participants in the U.S., U.K. and Japan. The schedule applies to “the trading of U.S. dollar-denominated government securities, mortgage- and asset-backed securities, over-the-counter investment-grade and high-yield corporate bonds, municipal bonds and secondary money market trading in bankers’ acceptances, commercial paper and

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Jan12

Investor Bulletin: 10 Investment Tips for 2016

The SEC’s Office of Investor Education and Advocacy released 10 tips to help investors make more informed decisions in 2016. Background Check Professionals Find background info on investment professionals on the SEC’s Investment Adviser Public Disclosure website. Get help from SEC toll-free investor assistance line at (800) 732-0330. Beware of Promises  The red flag of suspicion

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Jan09

Annual Contact Verifications for FINRA & MSRB Firms ~ Due Soon

Remember to fulfill these imminent annual FINRA & MSRB contact information obligations for 2016; FINRA Contact System Certification FINRA Super Account Administrator Certification MSRB Annual Contact Verification FINRA Contact System Certification Deadline FINRA rules require that member firms maintain a list of firm contacts in the electronic FINRA Contact System (FCS).  Update firm contact information within 30

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Jan09

FINRA’s 2016 Exam Priorities Letter ~ the Breakdown for Broker-Dealers

To support investor protection and market integrity, FINRA published its 11th annual Regulatory and Examination Priorities Letter.  FINRA continues to look into firm culture, ethics, and conflicts of interest.  However, this letter  pinpoints how examiners will formalize assessment of firm culture to better understand its impact on a firm’s compliance and risk management practices. Here’s

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Jan08

Securities-Backed Lines of Credit – What Investors Need to Know

Securities-backed lines of credit or SBLOCs are offered and marketed to investors by securities firms as a way to access extra capital—“a type of financing and liquidity strategy that can unlock the value of your investment portfolio.”  This can be appealing in a bull market, but market volatility can put your portfolio at risk. The

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Jan08

BDs and IAs ~ Reconcile FINRA Renewal Statements by 1-15-16

FINRA issued Final Renewal Statements and reports on Web CRD/IARD as of Jan. 4, 2016, for review and reconciliation by registered entities. The payment deadline is January 15, 2016 These statements reflect the final status of broker-dealer, registered representative, investment adviser firm, investment adviser representative, and branch registrations and/or notice filings as of December 31,

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Jan07

Outsourcing the CCO Role ~ OCIE Guidance for Advisers and Funds

The trend of investment advisers and funds outsourcing their compliance functions to third-party consultants prompted a study last quarter by the SEC Office of Compliance Inspections and Examinations (“OCIE”).  OCIE staff performed about 20 examinations under an “Outsourced CCO Initiative” to focus on SEC-registered investment advisers and investment companies (“registrants”) that outsource their CCO role.

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Jan05

What’s Driving FINRA’s New Compact CAB Status of Broker-Dealer?

The SEC seeks feedback on a proposed FINRA rule change to adopt a rule set covering a new, compact FINRA membership category—the capital acquisition broker or “CAB.”  This CAB rule set would generally cover non carrying brokers engaged in advising and raising capital for private placements with institutional investors or guiding mergers and acquisitions. Under

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Jan04

Broker-Dealer Annual Report Now Paper Free for the SEC

The SEC will finally allow broker-dealers to file their annual audited financial statement report or “Annual Audited Report” with the SEC electronically via the Electronic Data Gathering, Analysis and Retrieval system called EDGAR.  In a no action letter dated December 21, 2015, SEC’s Division of Trading and Markets Associate Director Michael A. Macchiaroli announced that annual

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Jan04

Supplemental Inventory Schedule 2016 Due Dates for Broker-Dealers

A firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I must file a Supplemental Inventory Schedule (SIS) unless the firm has: (1) a minimum dollar net capital or liquid capital requirement of less than $100,000; or (2) inventory positions consisting only of money market mutual

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Jan04

FOCUS Report 2016 Deadlines for Broker-Dealers

FINRA detailed the 2016 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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Jan04

Schedule of SSOI 2016 Filings for Broker-Dealers

FINRA issued the cutoff dates of Schedule for Supplemental Statement of Income (SSOI) filings for 2016. 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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Jan04

Form Custody Filing Schedule 2016 for Broker-Dealers

All broker-dealers must file Form Custody with their Designated Enforcement Agency (FINRA) at the same time as their quarterly FOCUS Reports. The 1st Form Custody filing is due January 27, 2016 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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Jan04

Form OBS 2016 Filing Due Dates ~ for Carrying and Clearing Broker-Dealers

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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Jan04

Audit Report Due Dates for Broker-Dealers 2016

FINRA reminded firms of their filing due dates for the annual certified audited report (“Annual Report”). Securities Exchange Act (SEA) Rule 17a-5(d)(6) requires every broker or dealer registered pursuant to Section 15 of the SEA to file an Annual Report. A completed SEC Form X-17A-5 Part III must accompany a firm’s Annual Report. File with

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Jan01

Financial Services Firms & FinTech ~ Prosper in the New Year with The SDDCO Group

Wishing our clients and colleagues a productive and prosperous 2016! In Need of Our Services? Reach out to The SDDCO Group of CPAs and Consultants at  info@sddco.com ~ 212-751-4422. About The SDDCO Group Formed in 1952, The SDDCO Group extends outsourced professional support to the financial services industry, including broker-dealers, investment advisers, commodity brokers, asset management

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