Broker Dealer | Compliance Programs | FINRA Rules | Regulatory Filings

Broker-Dealer Compliance “To Do” List for 2018

January

1/16/2018

  • Customer Complaint Quarterly Statistical Summary: For complaints received during the 4th Quarter, 2017.  FINRA Rule 4530 requires Firms to submit statistical and summary information regarding complaints received during the quarter by the 15th day of the month following the calendar quarter.

 1/22/2018

 1/25/2018

  • FINRA Contact System Annual Review: FINRA Rule 4517 requires Firms to review and, if necessary, update the required FINRA Contact System information within the first 17 business days of each calendar year.
  • MSRB Form A-12 Annual Affirmation. MSRB Rule A-12(k) requires each broker that is a member of the MSRB to review, update as necessary, and affirm the information in Form A-12 during the Annual Affirmation Period that begins on January 1 of each calendar year and ends 17 business days thereafter.
  • Rule 17a-5 Quarterly FOCUS Part II/IIA Filings:  For Quarter ending December 31, 2017. SEC requires that member firms file a FOCUS, (Financial and Operational Combined Uniform Single) Report Part II or IIA on a quarterly basis. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA.
  • Annual FOCUS Schedule I Filing for 2017: SEC requires all broker-dealers to submit operational information as of December 31st via the Annual FOCUS Schedule 1 Filing.
  • Quarterly Form Custody:  SEC requires that member firms file Form Custody pursuant to SEA Rule 17a-5(a)(5) for the quarter ending December 31, 2017.

1/29/2018

  • Annual Audit Reports for Fiscal Year-End November 30, 2017:  SEC requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of November 30, 2017.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

1/30/2018

  • Supplemental Statement of Income (“SSOI”): For the quarter ending December 31, 2017.  FINRA requires firms to submit additional, detailed information regarding the categories of revenues and expenses reported on the Statement of Income (Loss) page of the FOCUS Report Part II/IIA.
  • Supplemental Inventory Schedule (“SIS”): For the month ending December 31, 2017. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of June 30, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of December 31, 2017 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.

February

2/1/2018

  •  Form OBS: For the Quarter ending December 31, 2017.  Unless subject to the de minimis exception, all clearing, self-clearing, and carrying firms and those firms that have a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable derivatives and other off-balance sheet items must submit Form OBS as of the last day of a reporting period within 22 business days of the end of each calendar quarter via eFOCUS.  Firms that claim the de minimis exemption must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period.

 2/24/2018

March

3/1/2018

  • Annual Audit Reports for the Fiscal Year-End December 31, 2017:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • Supplemental Inventory Schedule (“SIS”): For the month ending January 31, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of December 31, 2017.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

3/2/2018

  • SIPC-6 Assessment: For firms with a Fiscal Year-End of July 31, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of January 1, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.

3/23/2018

3/28/2018

  • Supplemental Inventory Schedule (“SIS”): For the month ending February 28, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

3/30/2018

  • SIPC-6 Assessment: For firms with a Fiscal Year-End of August 31, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of February 28, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.

 April

4/2/2018

  • Annual Audit Reports for the Fiscal Year-End January 31, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of January 31, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

 4/16/2018

  • Customer Complaint Quarterly Statistical Summary: For complaints received during the 1st Quarter, 2018.  FINRA Rule 4530 requires Firms to submit statistical and summary information regarding complaints received during the quarter by the 15th day of the month following the calendar quarter.

 4/24/2018

  • Rule 17a-5 Quarterly FOCUS Part II/IIA Filings:  For Quarter ending March 31, 2018. FINRA requires that member firms file a FOCUS, (Financial and Operational Combined Uniform Single) Report Part II or IIA on a quarterly basis. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA.
  • Quarterly Form Custody:  SEC requires that member firms file Form Custody pursuant to SEA Rule 17a-5(a)(5) for the quarter ending March 31, 2018.

4/27/2018

  • Supplemental Statement of Income (“SSOI”): For the quarter ending March 31, 2018.  FINRA requires firms to submit additional, detailed information regarding the categories of revenues and expenses reported on the Statement of Income (Loss) page of the FOCUS Report Part II/IIA.
  • Supplemental Inventory Schedule (“SIS”): For the month ending March 31, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

 4/30/2018

  • Annual Audit Reports for Fiscal Year-End February 28, 2018. FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of March 31, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of September 30, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of February 28, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

May

5/1/2018

  • Form OBS: For the Quarter ending March 31, 2018.  Unless subject to the de minimis exception, all clearing, self-clearing, and carrying firms and those firms that have a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable derivatives and other off-balance sheet items must submit Form OBS as of the last day of a reporting period within 22 business days of the end of each calendar quarter via eFOCUS.  Firms that claim the de minimis exemption must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period.

 5/23/2018

5/29/2018

  • Supplemental Inventory Schedule (“SIS”): For the month ending April 30, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

 5/30/2018

  •  Annual Audit Reports for Fiscal Year-End March 31, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of April 30, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of October 31, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of March 31, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

June

6/25/2018

 6/28/2018

  •  Supplemental Inventory Schedule (“SIS”): For the month ending May 31, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

 6/29/2018

  •  Annual Audit Reports for Fiscal Year-End April 30, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC.   Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of April 30, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

July

07/2/2018

  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of May 31, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of November 30, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.

 7/16/2018

  • Customer Complaint Quarterly Statistical Summary: For complaints received during the 2nd Quarter, 2018.  FINRA Rule 4530 requires Firms to submit statistical and summary information regarding complaints received during the quarter by the 15th day of the month following the calendar quarter.

 7/25/2018

  • Rule 17a-5 Quarterly FOCUS Part II/IIA Filings:  For Quarter ending June 30, 2018. FINRA requires that member firms file a FOCUS, (Financial and Operational Combined Uniform Single) Report Part II or IIA on a quarterly basis. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA.
  • Quarterly Form Custody:  SEC requires that member firms file Form Custody pursuant to SEA Rule 17a-5(a)(5) for the quarter ending June 30, 2018.

07/30/2018

  • Annual Audit Reports for Fiscal Year-End May 31, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • Supplemental Statement of Income (“SSOI”): For the quarter ending June 30, 2018.  FINRA requires firms to submit additional, detailed information regarding the categories of revenues and expenses reported on the Statement of Income (Loss) page of the FOCUS Report Part II/IIA.
  • Supplemental Inventory Schedule (“SIS”): For the month ending June 30, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of June 30, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of December 31, 2017.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of May 31, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

August

8/1/2018

  • Form OBS: For the Quarter ending June 30, 2018.  Unless subject to the de minimis exception, all clearing, self-clearing, and carrying firms and those firms that have a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable derivatives and other off-balance sheet items must submit Form OBS as of the last day of a reporting period within 22 business days of the end of each calendar quarter via eFOCUS.  Firms that claim the de minimis exemption must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period.

8/23/2018

8/28/2018

  • Supplemental Inventory Schedule (“SIS”): For the month ending July 31, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

 8/29/2018

  • Annual Audit Reports for Fiscal Year-End June 30, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of June 30, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

8/30/2018

  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of July 31, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of January 31, 2018.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.

September

9/26/2018

October

10/1/2018

  • Annual Audit Reports for the Fiscal Year-End July 31, 2018: FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC.  Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • Supplemental Inventory Schedule (“SIS”): For the month ending August 31, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of August 31, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of February 28, 2018.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of July 31, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

10/15/2018

  • Customer Complaint Quarterly Statistical Summary: For complaints received during the 3rd Quarter, 2018.  FINRA Rule 4530 requires Firms to submit statistical and summary information regarding complaints received during the quarter by the 15th day of the month following the calendar quarter.

 10/24/2018

  • Rule 17a-5 Quarterly FOCUS Part II/IIA Filings:  For Quarter ending September 30, 2018. FINRA requires member firms to file a FOCUS, (Financial and Operational Combined Uniform Single) Report Part II or IIA on a quarterly basis. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA.
  • Quarterly Form Custody:  SEC requires that member firms file Form Custody pursuant to SEA Rule 17a-5(a)(5) for the quarter ending September 30, 2018.

10/29/2018

  • Supplemental Statement of Income (“SSOI”): For the quarter ending September 30, 2018.  FINRA requires firms to submit additional, detailed information regarding the categories of revenues and expenses reported on the Statement of Income (Loss) page of the FOCUS Report Part II/IIA.
  • Supplemental Inventory Schedule (“SIS”): For the month ending September 30, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

10/30/2018

  • Annual Audit Reports for the Fiscal Year-End August 31, 2018. FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of September 20, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of March 31, 2018.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of August 31, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

 10/31/201

  • Form OBS: For the Quarter ending September 30, 2018.  Unless subject to the de minimis exception, all clearing, self-clearing, and carrying firms and those firms that have a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable derivatives and other off-balance sheet items must submit Form OBS as of the last day of a reporting period within 22 business days of the end of each calendar quarter via eFOCUS.  Firms that claim the de minimis exemption must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period.

November

11/1/2018

  •  FINRA 2019 Renewal Program Preparations: Consult the FINRA website to access important dates and information regarding the 2019 Renewal Program.  Be sure to update your calendars and ensure your Renewal Account is sufficiently funded.

 11/27/2018

11/29/2018

  •  Annual Audit Reports for Fiscal Year-End September 30, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.

11/30/2018 

  • Supplemental Inventory Schedule (“SIS”): For the month ending October 31, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of October 31, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of April 30, 2018.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of September 30, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

December

TBD

 12/10/2018

12/26/2018

12/31/2018

  •  Annual Audit Reports for Fiscal Year-End October 31, 2018:  FINRA requires that member firms submit their annual audit reports in electronic form.  Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements.
  • Supplemental Inventory Schedule (“SIS”): For the month ending November 30, 2018. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, 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 funds.  A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of November 30, 2018 AND claiming exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970.  This annual filing is due within 30 days of the beginning of each fiscal year.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of May 31, 2018.  SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of October 31, 2018.  SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End.

General and On-going Obligations

  • Form BD Amendments: Firms are required to keep current the information filed on Form BD.  Amendments must be filed promptly whenever the information on file becomes inaccurate or incomplete for any reason.
  • Form U4 Amendments: Registered individuals and firms are required to keep current the information filed on Form U4.  Registered individuals must promptly notify the firm if any information changes or becomes inaccurate.  Firms must file amendments promptly upon becoming aware of changes to the information on file.
  • Form U5: Firms are required to submit a full termination for registered individuals within 30 days of the termination date.
  • Form 4530 Event Filing: FINRA Rule 4530 requires firms to report specified events to FINRA electronically through the Firm Gateway.  These reporting requirements are in addition to what the firm may need to report on Form BD.  Filings should be submitted promptly but in any event not later than 30 calendar days after the firm knows or should have known of the reportable event.
  • Form BR Amendments and Withdrawal: Firms are required to keep current the information filed on The Uniform Branch Office Registration Form (“Form BR”) for each registered office location.
  • MSRB Form A-12 Amendments and Withdrawal: Firms are required to keep current the information filed on MSRB Form A-12.  Amendments should be submitted within 30 days, if any information becomes inaccurate or if the firm ceases to be engaged in municipal securities or municipal advisory activities.
  • FinCEN Reviews: Firms are required by FinCEN to review requests and compare against list of customers and vendors and report hits to FinCEN within a certain period following the receipt of such request.

Annual Obligations

  • Annual Report of Compliance: FINRA Rule 3120 requires firms to designate one or more principals to establish, maintain, and enforce a system of supervisory control policies and procedures that test and verify that the firm’s supervisory procedures are reasonably designed to achieve compliance with applicable securities laws and regulations and with applicable FINRA rules. The designated principal or principals must submit to the firm’s senior management an annual report detailing each system of supervisory controls, the summary of the test results and significant identified exceptions and any additional or amended supervisory procedures created in response to the test results.
  • Annual CEO Certification: FINRA Rule 3130 requires the chief executive (or equivalent) officer to certify annually that the member has processes in place to establish, maintain, review, test and modify written compliance policies and written supervisory procedures reasonable designed to comply with applicable rules and regulations and that the CEO has had one or more meetings with the CCO in the preceding 12 months to discuss the processes.  This annual certification must be executed no later than the anniversary date of the previous year’s certification.
  • Annual Compliance Meeting: FINRA Rule 3110 (a) requires each registered representative and each registered principal to participate in an annual interview or meeting to discuss compliance matters relevant to the activities of the participants.
  • Firm Element Continuing Education Plan: As per FINRA Rule 1250, each member must maintain a continuing and current education program for its covered registered persons.  Each year, firms must evaluate and prioritize their training needs and document such in a written training plan.
  • Office Inspection Program: Firms are required by FINRA Rule 3110(c) to review the activities of each office and retain a written record of the date upon which each review and inspection is conducted.  OSJs and branch office that supervise one or more non-branch locations must be inspected annually.  Branch offices that do not supervise or nor more non-branch locations must be inspected at least every three years.  Non-branch locations should be inspected every three years.  The firm is required to report inspection results in a written report to be maintained for a minimum of three years or until the next inspection, whichever is longer.
  • Notifications to Customers:  Firms are required to provide customers with various notifications on an annual basis.  Notifications include, but are not limited to Investor Protection and Education, Payment for Order Flow, Order Routing Information, SIPC, Privacy Policy,  and Business Continuity.

Keeping up the latest compliance regulations can be daunting, contact Hardin Compliance Consulting LLC for our Comprehensive Compliance Services that you can rely on.

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