cordium webinar: broker dealer year-end to do list 2014

November 21, 2014FINRA REGISTERED BROKER-DEALER YEAR-END TO DO LIST 1

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FINRA REGISTERED BROKER-DEALERYEAR-END “TO DO” LIST November 19, 2014

Presented By:

John Donegan Vice President, Broker Dealer & AML Consulting

Cordium

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Agenda

November 2014FINRA REGISTERED BROKER-DEALER YEAR-END TO DO LIST 5

o FINRA Renewal Programo 2015 Renewal Program Calendar o Very Important Reminderso Other Items of Concern for

Year-End Compliance Review

Introduction

As the year-end approaches, many FINRA Registered broker-dealers are wondering if they have addressed all their compliance obligations for the year, as well as contemplating if there are needs to be addressed by December 31st.


FINRA Renewal Program

o Broker-dealers are encouraged to review the registrations of each of its representatives to ensure; o the states where they need to be registered are still

accurate;o and that all open branch offices have individuals assigned

to them and are properly designated as either a registered branch or an OSJ.



o Firms have the opportunity to submit post-dated U5s, BR Closures, and BDWs in advance of the Preliminary Renewal Statements being issued.

o FINRA will begin allowing post-dated filings to be submitted beginning Nov 1st.

o All post-dated forms must reflect an effective date of Dec 31, 2014.

o There is more about the 2015 Renewal Program Calendar on FINRA’s website.

November 2014 8FINRA REGISTERED BROKER-DEALER YEAR-END TO DO LIST


o Firms are required to pay the entire balance of the Preliminary Renewal Statement, regardless of whether or not reps are added or removed during the Renewal period.

o It is always advisable for broker-dealers to review registrations and to make required changes in post-dated or current filings prior to the Preliminary Renewal Statements being printed.

o Full payment of the Preliminary Renewal Statement balance is due to FINRA no later than Dec 12th.



o Web CRD® will be closing for the year on December 26th at 6:00pm ET - submit all Web CRD® filing requests to your account manager by Dec 19th to ensure filings are processed prior to the shutdown.

o If registration changes are made (U4, U5, BR Closure, BDW) between Nov 8th and Dec 26th, the renewal difference will be reflected on the Final Renewal Statement, which will be issued Jan 2, 2015.



o Overpayments will automatically transfer from the Renewal Account to the Daily Account on December 19, 2015 as well. Should a broker-dealer find there is a substantial amount of money credited to their Daily Account, a refund can be requested.

o The deadline for Final Renewal Statement balance payments and reporting any Renewal Discrepancies is February 2, 2015.


2015 Renewal Program Calendar:October 2014

o 1st – FINRA suggests firms review their registered persons to ensure that they have properly and timely reported all appropriate information to Web CRD® and that all open branch offices have individuals assigned to them and are accurately reported.

o 27th – Firms may begin to submit post-dated Forms U5 and BR Closing/Withdrawal, which must be dated 12/31/14.


2015 Renewal Program Calendar:November 2014

o 1st – Firms may begin to submit post-dated Forms BDW and ADV-W, which must be dated 12/31/14.

o 8th – Web CRD® and IARD are unavailable as Preliminary Renewal Statements are generating.

o 10th – PRELIMINARY RenewalStatements and reports are available for viewing and printing.


2015 Renewal Program Calendar:December 2014

o 12th – DEADLINE for receipt of Preliminary Renewal Statement payments.

o 15th – Automatic Transfers: Firms with sufficient monies in their Flex-Funding Account will have funds transferred to their Renewal Account to cover total renewal fees owed. o Transfers will be conducted every day until Web

CRD®/IARD shuts down for year-end processing.


2015 Renewal Program Calendar:December 2014 (continued)

o 27th – LAST DAY to submit form filings prior to year-end. Web CRD® and IARD are available from 8 a.m. until 6 p.m., Eastern Time (ET).

oNOTE: FINRA will be closed on Saturday, December 27 and FINRA staff support is unavailable. Therefore, Forms U4 and BD filing/deficiencies (e.g., Disclosure Review) will not be manually reviewed by staff until full system functionality resumes on January 2, 2015.

o 29th – Web CRD® and IARD are unavailable due to Final Renewal Statement and renewals processing.

o 30th & -31st – Web CRD® and IARD are available for QUERY-only and the creation of "Pending" filings.


2015 Renewal Program Calendar:January 2015o 1st – Web CRD® and IARD are unavailable due to the holiday schedule.o 2nd – Web CRD® and IARD are available with complete functionality as of

5 a.m., ET, including submitting form filings and approving registrations.o Overpayments are transferred to firms' Flex-Funding Account. Refund

requests should be made from this account.o Final Renewal Statements and reports are available for viewing and printing.

o 16th – DEADLINE for receipt of Final Renewal Statement payments.

o 20th – Automatic Transfers: Firms with sufficient monies in their Flex-Funding Account will have funds transferred to their Renewal Account to cover total renewal fees owed. Transfers will be conducted every day until any outstanding renewal assessment is satisfied.


VERY IMPORTANT REMINDERS

o Registered persons should review their Form U4 and Form U5 to ensure: o Information on Form U4 is updated and correct (residential and employment

history; any applicable disclosures)

o The broker-dealer should review registered representative files to ensure: o Written acknowledgement of firm’s compliance manual(s) have been receivedo All Outside Business Activities have been reported and are up to dateo All proper documentation is on file for any private securities transactionso All outside brokerage accounts have been reported and you are receiving

statements/confirms as per the broker-dealers procedureso Any political contributions have been reported to firm, if applicableo All registered persons are registered in applicable jurisdictions


Other Items of Concern for Year-EndCompliance Review

o Review of firm’s website for accuracy and proper disclosureso Ensure annual Privacy Policy delivery requirements were met

for 2014o Review, document, test and update as necessary the firm’s

Business Continuity Plano Completion by all registered persons of

the Annual Compliance Questionnaireo Conduct annual independent testing of the

firm’s Anti-Money Laundering program


Other Items of Concern for Year-EndCompliance Review (continued)

o Ensure that branch and OSJ exams have taken place per firm’s inspection cycle

o Ensure all attestations have been signed and returned – i.e. manual attestations, Outside Business Activities, Outside Brokerage Accounts

o Ensure annual Compliance meeting has been held and documentation on attendance is maintained

o Ensure firm Element training requirements have been documented and requirements are complete

o Ensure annual OFAC of existing clients has been run


Contact Us

Cordium is here to help you make sure you have all the tools and information to make the end of year go smoothly.

For further information please email: [email protected]


mailto:[email protected]

cordium webinar: broker dealer year-end to do list 2014

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