Broker-dealers are facing an increasing number of regulations from and responsibilities to a variety of authorities. These include Federal and State government agencies as well as a host of self-regulatory organizations. Our broker-dealer consulting, registration, compliance services and continuing guidance are tailored to meet the needs and requirements of new and existing broker-dealer firms.
Our broker-dealer consulting offerings are provided by professionals tenured with decades of industry or regulatory (or both) experience — and range from broker-dealer registration services for new firms to broker-dealer compliance services for existing firms.
Throughout our broker-dealer registration services, we shepherd our broker-dealer clients through the time-consuming steps and process necessary for an Initial Registration:
Compliance has never been so complex. Our broker-dealer compliance services assist firms to not only meet a growing environment of regulatory requirements but to set the foundation for a culture that will promote best practices in compliance throughout its offices.
We provide ongoing updates to your firm’s Written Supervisory Procedures in response to changes to:
Test supervisory and compliance procedures
Prepare a written report for the requirements of FINRA Rule 3120(a) detailing the system of supervisory controls, the summary of the test results and exceptions, and any additional or amended supervisory procedures created in response to the test results
FinOp – Work with your designated in-house or external Financial and Operations Principal to assess your process for creating and filing your FOCUS and SSOI reports
Review your firm’s FINRA Rule 3130 policies and procedures
Review documentation of required CEO and CCO meetings
Review testing documentation
Draft FINRA Rule 3130 Annual CEO Report
Anti‐Money Laundering —AML Compliance Testing – In compliance with the FINRA Rule 3310 requirement to independently test each broker‐dealer’s AML compliance program, we will conduct an AML compliance review to test and analyze the effectiveness and efficiency of your firm’s AML program.
AML Training – Prepare and present annual AML training materials.
Review how your firm creates, reviews and maintains marketing and advertising materials
Review and test electronic communications surveillance system parameters
Advertising – Submit all advertising required for filing with FINRA
Continuing Education Needs Analysis and Training Plan – Help prepare your annual Continuing Education and Training Plan
Annual Compliance Meeting – Prepare and present materials for the annual compliance meeting via an on‐demand webcast which also tracks attendance and produces an attestation of completion
Regulatory Continuing Education – Monitor and notify individuals of the dates for completion of their Regulatory Element Continuing Education
FINRA Examination Response Program – For Sales Practice, FinOp, MSRB, special exams, or sweeps by FINRA, we provide onsite and offsite assistance prior to the exam in the form of a mock audit to identify potential deficiencies and initiate corrective action; during the exam, serving as your contact person with FINRA, participating in FINRA reviews and assisting with document requests. We are also available to assist you and your counsel with SEC examinations
Deficiency Letter Response – Prepare written responses to FINRA in response to issues presented during examinations
Offsite Assistance with Informal FINRA Regulatory Inquiries – Assist in responding to regulatory inquiries
Review the activities of each OSJ and supervisory branch office at least annually, nonsupervisory branch offices at least every three years, and non‐branch locations on a regular, periodic schedule.
Provides completed checklists and reports of each review
Review your firm’s designation of its principals for OSJs and non‐OSJs and will review supervisory personnel qualifications for the experience or training necessary to be qualified to carry out their assigned responsibilities, as well as the design of the supervisory system to meet the on-site requirement
Customized Telephone Consulting – Your designated Bates broker-dealer compliance professional will be available to answer questions from your firm’s compliance personnel
CRD Administration – Complete all CRD filings with state and federal regulators (including Form U4 and U5 filings)
Quarterly Customer Complaint and Disclosure Filings – Assist in determining and filing customer complaints and disclosures with FINRA
Ongoing Form BD and Form BR Review –Review and amend Forms BD and BR when required
Our broker-dealer consulting, registration, and compliance services offerings are provided by experts tenured with decades of industry and/or regulatory experienceContact Bates Group