Can’t Help but Dwell: My apologies for beating the dead horse that comprises some of the less noticeable points contained in FINRA’s still recent (in the scheme of major rule changes) revision of the licensing schemata of October 2018. This post is short and sweet. Let’s discuss Permissive Registrations, shall we? But first, in case… Read More »
FINRA’s New Principal Financial Officer and Principal Operating Officer Designations. What Happened to my FINOP?
Some (Very Recent) Background Effective October 1, 2018, FINRA member broker-dealers are required to designate a Principal Financial Officer (“PFO”) and a Principal Operations Officer (“POO”). PFOs and POOs are now required at all broker-dealer firms. FINRA expects that the PFO would have primary responsibility for financial filings and related books and records. The… Read More »
FINRA’s New Licensing Requirements
In late 2017 FINRA provided notice of a series of changes to be made to the Qualification and Registration rules. On October 1, 2018 those changes became effective. One of the most interesting changes, for no other reason than that it concerns the creation of a new level of qualification and hence a new… Read More »
AML CIP for Private Placement Broker-Dealers
A broker-dealer is required as part of its Anti-Money Laundering (AML) procedures to develop a Customer Identification Program or “CIP.” A broker-dealer follows its CIP as it attempts to verify the identity of individuals or entities, who are in most cases its customers, wishing to conduct financial transactions with the broker-dealer. Both the AML… Read More »
Selling or Buying a Broker-Dealer: When Can You Close? When Should You?
The FINRA rule governing the sale (and purchase, by extension) of a broker-dealer firm is the most counter-intuitive rule in the history of rule-making. Maybe a little dramatic there but it’s my blog post, that’s my story, and I’m sticking to it. I meet many of my clients at the beginning of the process… Read More »