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Printer-Friendly Last Updated: 4/2/08 Small Firms Regulatory Deadlines

Following is a listing of regulatory deadlines of interest to small FINRA member firms. This information will be updated on a regular basis and notice of updates to this page will be included in the weekly e-mail message to firm Executive Representatives as deadlines near.

Regulatory Deadlines

Annual Deadlines with No Fixed Date

Regulation S-P
SEC Regulation S-P, which went into effect on July 1, 2001, requires that firms provide an annual notice regarding their privacy policies to each customer during the continuation of the customer relationship. See Notice to Members 00-66; SEC Release 34-42974 (June 22, 2000), 65 FR 40334 (June 29, 2000).

Analysts: Senior Management Annual Attestation re Procedures

NASD Rule 2711 requires a senior officer of each NASD member firm subject to NASD Rule 2711 to attest to NASD by April 1 of each year that:

(i) The member has adopted and implemented written supervisory procedures reasonably designed to ensure that the member and its employees comply with the provisions of NASD Rule 2711; and
(ii) The member certifies that the committee responsible for reviewing and approving each research analyst's compensation has reviewed and approved each such research analyst's compensation and documented the basis upon which this compensation was established.

The NASD Rule 2711 Annual Attestation required to be filed by April 1 may be submitted to NASD in paper-based format, or alternatively, firms can file the attestation through an electronic, Internet-based receiving and processing system. The electronic filing system is available on NASD's Web site: http://www.nasd.com/regnotes2711

Members (or persons designated by the member) with the ability to electronically file designated regulatory notices with NASD by using the NASD Entitlement System will have access to this new online form. Users who do not have an NASD Entitlement account and need access to the new online form should see their Regulation Filing Account Administrator.

If your firm wishes to file the attestation in paper-based format, please submit it via facsimile to (866) 397-3290, or mail to the following address:

Attention: Research Analyst Attestation
Examination Programs, Member Regulation
NASD
1735 K Street, NW
Washington, DC 20006-1506

Please note that NASD has provided Rule 2711 guidance to members in the following Notices to Members: 02-39, 02-44, "For Your Information November 2002", 03-44, 04-18, 04-25, 05-14, 05-24, and 05-34.

AML: Information Sharing

The Financial Crimes Enforcement Network's (FinCEN's) rule regarding information sharing among financial institutions for the purpose of identifying, preventing, and deterring money laundering and terrorist activity requires that financial institutions (broker/dealers), after filing an initial notification with FinCEN, must also file an annual notice. The notification may be completed online at FinCEN's Web Site. (See AML Web page and AML FAQ for more information regarding the requirements with complying with information sharing regulation.)