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


What RIAs Should Know about Predecessor Registrations

In November 2016, the staff of the SEC’s Division of Investment Management  (“Division Staff”) released an IM guidance Update on Investment Advisers Reliance on Predecessor Registrations.   This guidance covers how and when an entity may rely on a predecessor’s registration as an SEC registered investment Adviser (“RIA”).  Please note that Division Staff guidance while helpful

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SEC Approves Plan for U.S. Market Data Source

The SEC  approved a national market system (NMS) plan to create a single, comprehensive database—the consolidated audit trail (CAT)—to enable regulators to better track all trading in the U.S. equity and options markets.  The NMS plan will detail how self-regulatory organizations (SROs) and broker-dealers (BDs) will record and report information, and explains how the data

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SEC Relief for Broker-Dealers ~ Operating Leases under Rule 15c3-1

An SEC No Action Letter to SIFMA, dated November 8, 2016, assures the Division of Trading and Markets staff (“Division”) would not recommend enforcement action to the SEC (under SEA Rule 1 Sc3-1) if a broker-dealer treats the asset and liability arising from an operating lease in the manner described below. The FASB Trigger The

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SEC to Modernize Small Biz Capital Formation via Intrastate and Small Offerings

On October 26, 2016, the SEC adopted final rules to update how companies can raise money to fund their businesses through intrastate and small offerings. According to SEC Chair Mary Jo White, “These final rules, while continuing to provide investor protections, update and expand the capital raising avenues for smaller companies, allowing them to more

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FINRA ‘‘Pay-To-Play’’ Rules ~ Effective August 20, 2017

On August 25, 2016, the SEC approved new FINRA rules governing political contribution matters tied to the award of advisory business.  Per FINRA Regulatory Notice 16-40 ~ Political Contributions, the FINRA “Pay-to-Play Rules” aim to regulate the pay-to-play activities of FINRA member broker-dealers compensated for engaging in distribution or solicitation activities on behalf of investment

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2017 Renewals for Investment Advisers & Broker-Dealers ~ Deadline Dec. 16th

The payment deadline for the 2017 Renewal Program of Broker-Dealer, Investment Adviser Firm, Agent and Investment Adviser Representative, and Branch Renewals is December 16, 2016. As of November 14, 2016, FINRA will make the online Preliminary Statements available to all firms in E-Bill. Key Renewal  Dates: October 24, 2016: Firms could begin submitting post-dated Form

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MSRB Invites Feedback on SRO Planning

As part of its next strategic planning cycle, starting January 2017, the Municipal Securities Rulemaking Board (MSRB) is seeking public input on its long-term priorities to help guide the strategic direction of the organization. Request for Comment The MSRB is seeking public comment regarding its long-term priorities and initiatives as they relate to core activities

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A Trade Confirmation Ain’t from the SEC!

The SEC’s Office of Investor Education and Advocacy issued an Investor Alert to warn about  investment schemes in which fraudsters send fake Forms 4 to investors claiming the investor paid for the purported purchase of shares. Fraudsters may pose as brokers pretending to sell pending IPO or pre-IPO shares of well-known companies: They may use official looking forms that

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Retail BD Communications with the Public ~ Eased Rules Effective Soon

The SEC has approved eased communication filing requirements for FINRA broker-dealers (“firms”) related to registered investment company (RIC) shareholder reports, non-predictive retail communications, ranking and comparison backup material for communications holding fund performance, investment analysis tool templates, and bond mutual fund volatility ratings. The following rules were impacted: FINRA Rule 2210 (Communications with the Public)

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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