Guidance
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The Reg NMS Trade Through Report Card is a monthly statistical report detailing the transactions in NMS Securities that appear to have been reported by your firm to a Trade Reporting Facility ("TRF") or to FINRA's Alternative Display Facility at a price that traded through at least one protected best bid or offer at the respective time of execution. If non-compliance with the Order Protection Rule of Regulation NMS is found to exist, your firm may be found to be in violation of SEC Rule 611 of Regulation NMS.
Overview
FINRA is providing this checklist to help members assess their obligations under the SEC’s Regulation Best Interest (Reg BI) and Form CRS Relationship Summary (Form CRS). The checklist is not a substitute for any rule. Only the rule can provide definitive information regarding its requirements. Interpretive questions should be directed to the SEC, at [email protected].
FINRA360 has yielded a number of organizational and operational changes aimed at making FINRA a more efficient, more effective regulator.
The MSRB G-32 Report Card is a monthly status report to help firms evaluate the timeliness of their required filings under Municipal Securities Rulemaking Board (MSRB) Rule G-32. Amended Rule G-32, which became effective on June 1, 2009, consolidated the filing requirements of former Rule G-36 and the official statement delivery requirements of Rule G-32.
1. My firm filed with the Advertising Regulation Department a retail communication that promotes or recommends a private placement subject to the filing requirements of FINRA Rules 5122 or 5123. Do we now need to file the same communication with the Corporate Financing Department?
Overview
When considering their obligations to provide all available breakpoint discounts on sales of Class A shares of front-end load mutual funds, member firms may review the following Breakpoint Checklist and Breakpoint Worksheet, which may help member firms evaluate their breakpoint compliance programs and confirm whether they are capturing all relevant categories of information to provide customers all available breakpoint discounts.
Background
Input from our stakeholders indicated that they would welcome greater transparency regarding FINRA's budget, especially its financial projections and potential use of fines. FINRA for many years has published an Annual Financial Report that is prepared and audited in accordance with GAAP6 that describes the prior year's finances and operations.
The Underwriter Financial Status Report is a monthly report designed to help firms evaluate the timeliness of financial disclosures made to EMMA, for issuances previously brought to market.
The purpose of this report is to highlights issuances lacking current audited financial filings (LCF) and the lateness of these missing financial filings, based on their anticipated filing time line.
The report offers two alternate views:
Background
Another issue we are studying through the lens of FINRA360 is branch office inspections. The responsibility of firms to supervise their associated persons is a critical component of federal broker-dealer regulation. Over the last few years, and in comments we have recently received, firms have raised questions about the manner in which they must conduct internal inspections, particularly for those offices or locations with a limited number of associated persons or where only operational or limited supervisory functions take place.
Regulatory Obligations
Exchange Act Rule 15c3-3 (Customer Protection Rule) requires firms that maintain custody of customer securities and safeguard customer cash to segregate these assets from the firm’s proprietary business.
The Sales Practice Complaint Report is a quarterly report that displays trends in complaints with Sales Practice problem codes as reported to FINRA pursuant to FINRA Rule 4530. Note: prior to July 1, 2011, this report showed complaints reported pursuant to NASD Rule 3070(c) or NYSE Rule 351(d). For the purposes of the report, Sales Practice Complaints are evaluated against the number of representatives registered with the firm and the sales revenue of the firm.
The Financial Crimes Spotlight is a free webinar series hosted by FINRA’s Financial Intelligence Unit that focuses on how to detect and protect against emerging financial crimes and cyber-related threats and trends.
These events are open to FINRA member firms only. Participants must provide their firm's broker-dealer number when registering.