Guidance
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In addition to the Small Firm Helpline, FINRA has implemented other programs for small firms:
The Contra Reporting Firm 20 Minute Compliance Report Card is a monthly status report on compliance for market participants with the requirement that Contra Firms accept / decline / compare trades within 20 minutes of trade execution. It provides information about the number of trades that were accepted / declined / compared within 20 minutes of execution, along with the number of trades that were accepted / declined / compared greater than 20 minutes after execution time, as well as the percentage of those trades to total trades executed.
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 tradingandmarkets@sec.gov.
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
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.
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?
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: