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FINRA Compliance Vendor Directory

October 31, 2018
Volume 44

  • Regulatory Notice
  • SEC Staff No-Action Letter
disciplinary actions

Disciplinary Actions


Upcoming Deadlines and Effective Dates
  • FINRA Requests for Comment

Education and Compliance Programs

The FINRA Compliance Vendor Directory (CVD) provides firms a convenient, effective way to search for vendors that offer the following compliance-related services. FINRA recently added new features to the CVD that enable firms to:

  • perform a keyword search for terms included in a vendor’s compliance description;
  • compare compliance offerings side-by-side for up to three vendors; and
  • filter and view vendors with small firm (less than 150 registered representatives) clients.

Visit our website for more information on how to search the CVD or list your company as a vendor.

Check out the new Advertising Regulation Department webpage. FINRA reorganized the Advertising Regulation web pages to make it easier for visitors to navigate and find the content they need, including the advertising rules and interpretive guidance. New sections include a consolidated FAQ and specific guidance on what, when and how to file communications with the Advertising Regulation Department. We also added a new feature with content specifically for new and pending member firms.

FINRA Elections

Three FINRA elections to fill vacancies on the Regional Committees, the Small Firm Advisory Committee (SFAC) and the National Adjudicatory Council (NAC) are underway. Ballots for each election are due November 15, 2018. The candidates running for election are listed in the following Election Notices:

In addition, FINRA is conducting a Special Election to fill a Small Firm Vacancy on the National Adjudicatory Council. Petitions for candidacy are due December 13, 2018. Any eligible individual who obtains the requisite number of valid petitions may be included as a candidate on the ballot by following the petition procedures set forth in FINRA Regulation’s By-Laws and Election Notice 10/29/18.


Broker-Dealer, Investment Adviser Firm, Agent and Investment Adviser Representative, and Branch Renewals for 2019

The 2019 Renewal Program begins on November 12, 2018, when FINRA makes the Preliminary Statements available to all firms in E-Bill. As described in Regulatory Notice 18-37, the payment deadline is December 17, 2018.

SEC Staff No-Action Letter: Treatment of Operating Leases under SEA Rule 15c3-1

On October 23, 2018, the staff of the SEC’s Division of Trading and Markets issued a no-action letter that provides specified relief to broker-dealers with respect to the treatment of operating leases under SEA Rule 15c3-1. The October 23, 2018, letter replaces a previous letter that the SEC staff had issued on November 8, 2016, which the SEC staff stated is withdrawn.

 Disciplinary Actions

FINRA publishes disciplinary actions to remind registered representatives and firms of specific conduct that violates FINRA rules and may result in disciplinary action. FINRA posted the following disciplinary item on the website this week:

  • FINRA fined LPL Financial, LLC $2.75 million for complaint-reporting and AML program failures that spanned a period of more than three years. FINRA found that LPL failed to file or amend registered representatives’ Forms U4 or U5 to disclose dozens of reportable customer complaints.

 Upcoming Deadlines and Effective Dates

FINRA Requests for Comments

FINRA has three open requests for comments.

FINRA requests comment from member firms and other interested parties on enhancements to the Securities Industry Continuing Education Program (CE Program) under consideration by the Securities Industry/Regulatory Council on Continuing Education (CE Council). These enhancements include the transition of the Regulatory Element program to a more focused and shorter learning requirement administered annually. The CE Council is also gathering feedback on the current Firm Element program and supporting resources as well as on the overlap of the Firm Element program with other firm training requirements. The program enhancements that are under consideration are published on the CE Council’s website and in Regulatory Notice 18-26. Comments are due November 5, 2018.

FINRA requests comment on a proposal to expand the summary firm data relating to over-the-counter (OTC) equity trading that FINRA publishes on its website by (1) publishing on a one-month delayed basis new monthly aggregate block-size trading data for OTC trades in NMS stocks executed outside an alternative trading system (ATS); (2) publishing aggregate non-ATS volume for all firms, by eliminating the existing de minimis exception; and (3) separately identifying firms’ volume of trading on a single dealer platform (SDP), by requiring firms to use a unique market participant identifier (MPID) when reporting their SDP trades to FINRA. The proposal is described in Regulatory Notice 18-28 and comments are due November 12, 2018.

FINRA released a white paper outlining recent regulatory technology (RegTech) developments within the securities industry and potential opportunities and implications these technologies may have for broker-dealers. FINRA highlights five areas where industry participants have most prominently leveraged RegTech innovations: surveillance and monitoring, customer identification and antimoney laundering compliance, regulatory intelligence, reporting and risk management and investor risk assessment. FINRA has requested comments and feedback from interested parties by November 30, 2018.


 Education and Compliance Programs

Register today for FINRA's upcoming AML Half-Day Seminar, which takes place November 6 in Boca Raton. The seminar is designed for AML compliance professionals from firms of all sizes who are new to their role, or who are looking to reinforce their understanding of regulatory requirements and compliance responsibilities.

Visit FINRA's website to learn more and to register.

Register today for the New York Region Member Forum, which takes place December 6. The forum provides an opportunity for participants to engage in key discussions with FINRA staff and industry peers around the future landscape of the financial services industry. There is no cost to attend, but attendance is limited to FINRA firms headquartered in the New York Region, and is first come, first served.

The FINRA Small Firm Conference is sold out and we currently have a waitlist. If you are looking for other educational offerings, register today for the 2019 FINRA Annual Conference—which includes sessions designed specifically for small firms.

The Annual Conference takes place May 15-17, 2019 in Washington, DC. Reduced rates are available for the first 500 in-person registrants before March 29, 2019. Register today.

Also coming up:

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