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FINRA Rule 7470 contains a provision that permits FINRA to grant exemptive relief from the OATS reporting and recording requirements for manual orders in certain circumstances, for example, where reporting of such information would be unduly burdensome for the member or where temporary relief from the rules would permit the member to avoid unnecessary expense or hardship (in the form of additional time to achieve compliance).
The TRACE Reporting section of the 2017 Report on Exam Findings informs member firms’ compliance programs by describing recent findings and observations from FINRA’s examinations, and, in certain cases, also providing a summary of effective practices.
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FINRA observed some instances in which firms have had difficulty meeting various aspects of their obligations under Regulation SHO and relevant FINRA rules:
Supervision of Third-Party Order Management Systems – FINRA found that some firms may be overly reliant upon a third-party order management system for supervisory and compliance functions. FINRA noted inadequate levels of firm
The Order Capacity section of the 2017 Report on Exam Findings informs member firms’ compliance programs by describing recent findings and observations from FINRA’s examinations, and, in certain cases, also providing a summary of effective practices.
The Net Capital and Credit Risk Assessments section of the 2017 Report on Exam Findings informs member firms’ compliance programs by describing recent findings and observations from FINRA’s examinations, and, in certain cases, also providing a summary of effective practices.
To assist firms in making the transition to the Form BR, NASD used data previously filed on Schedule E, the NYSE Branch Office Application Form, and/or state branch office forms to create a branch record on the Web CRD system for all existing branch offices. The data used was the data on file in Web CRD as of close of business, Friday, October 14, 2005.Firms had until July 3, 2006, to comply with
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FINRA has identified instances in which firms that carry customers’ alternative investment assets held in IRAs failed to apply the requirements of financial and operational rules applicable to those assets.20
Failure to Establish Possession or Control as Required by SEA Rule 15c3-3 (referred to as the SEC’s “Customer Protection Rule”) – In some instances, firms that maintained custody
The Market Access Controls section of the 2017 Report on Exam Findings informs member firms’ compliance programs by describing recent findings and observations from FINRA’s examinations, and, in certain cases, also providing a summary of effective practices.
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Best execution is a significant investor protection requirement that essentially obligates a broker-dealer to exercise reasonable care to execute a customer's order in a way to obtain the most advantageous terms for the customer. As the circumstances of each order and trading environment vary, so does the determination of what is best execution. Broker-dealers must be cognizant of
