Guidance
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Background
In response to the March 2017 Special Notice on Engagement issued as part of FINRA360, FINRA received a number of comments and suggestions regarding the effectiveness of communications with and education of firms, including ways in which FINRA could enhance its engagement with member firms. After careful review of the comments and suggestions received, FINRA is taking a number of actions.
Background
FINRA’s highest priority when it identifies misconduct is to seek restitution for harmed investors. However, like many other self-regulatory organizations in the securities industry, FINRA also imposes fines on its members to discourage further misconduct. Fine amounts are based on public, pre-established guidelines and the facts and circumstances of the individual case. FINRA does not target any minimum amount of fines to be collected.
The Reporting Firm 10 Second Compliance Report Card are monthly status reports for market participant that contain counts of properly modified late trades, late trades that were not modified, and improperly modified trades.
Reporting Firm is defined as the firm that reported the Executing Party of the trade.
FINRA is committed to ensuring that all respondents are treated fairly in expedited proceedings. Below, you will find brief answers to a number of questions frequently asked by respondents. We hope these answers will be helpful in orienting you to the process for expedited proceedings.
From cybersecurity to new product review, the FINRA Peer-2-Peer Compliance Library is a one-stop source for templates, checklists and other materials provided by FINRA-registered firms as supplemental resources at FINRA events. Investment professionals can browse the library after logging in with FINRA Gateway credentials. If you have feedback on the Peer-2-Peer Compliance Library, send an email to Member Relations and Education.
In addition to the Small Firm Helpline, FINRA has implemented other programs for small firms:
The Contra Reporting Firm 20 Minute Compliance Report Card is a monthly status report on compliance for market participants with the requirement that Contra Firms accept / decline / compare trades within 20 minutes of trade execution. It provides information about the number of trades that were accepted / declined / compared within 20 minutes of execution, along with the number of trades that were accepted / declined / compared greater than 20 minutes after execution time, as well as the percentage of those trades to total trades executed.
The Reg NMS Trade Through Report Card is a monthly statistical report detailing the transactions in NMS Securities that appear to have been reported by your firm to a Trade Reporting Facility ("TRF") or to FINRA's Alternative Display Facility at a price that traded through at least one protected best bid or offer at the respective time of execution. If non-compliance with the Order Protection Rule of Regulation NMS is found to exist, your firm may be found to be in violation of SEC Rule 611 of Regulation NMS.
Overview
FINRA is providing this checklist to help members assess their obligations under the SEC’s Regulation Best Interest (Reg BI) and Form CRS Relationship Summary (Form CRS). The checklist is not a substitute for any rule. Only the rule can provide definitive information regarding its requirements. Interpretive questions should be directed to the SEC, at [email protected].
The MSRB G-32 Report Card is a monthly status report to help firms evaluate the timeliness of their required filings under Municipal Securities Rulemaking Board (MSRB) Rule G-32. Amended Rule G-32, which became effective on June 1, 2009, consolidated the filing requirements of former Rule G-36 and the official statement delivery requirements of Rule G-32.
1. My firm filed with the Advertising Regulation Department a retail communication that promotes or recommends a private placement subject to the filing requirements of FINRA Rules 5122 or 5123. Do we now need to file the same communication with the Corporate Financing Department?