Comments on NASD Notice to Members 04-45

In the explanation of terms you define " person-in-charge " as a natural person who is physically located at the branch and who has been designated to supervise the activities of the individuals working at the branch. In the Form BR it states that any application submitted without a person-in-charge is deemed an incomplete application.


My question is what about registered branches that are maintained by only one or two licensed associates and there is no person physically located at the location as the person-in-charge. The licensed associate(s) are supervised by the principal located at the OSJ ???


Jeff Maxwell
SVP Compliance
UMB Scout Brokerage Services
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