Guidance

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.

FINRA has enhanced its engagement with key stakeholders to provide greater transparency and foster dialogue that helps us better understand the industry and markets we regulate.

Question 1

Does FINRA Rule 3210 impose any requirement as to what specific information or data an employer member must review or monitor upon receiving duplicate copies of confirmations and statements, or the transactional data contained therein, with respect to an account subject to the rule?

Answer

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.

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].

Background

In March 2017, FINRA issued a Special Notice on its engagement programs as part of FINRA360. Based on comments and suggestions regarding the usefulness of some advisory committees, their membership and their effectiveness as a vehicle for dialogue between FINRA and member firms, FINRA is making several changes.

Operational Impact of Rule Changes

 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?

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 ways in which FINRA could help facilitate compliance among its member firms. One of FINRA's defining characteristics as a self-regulatory organization (SRO) is the ability to develop compliance tools and other resources to assist our members with fulfilling their compliance obligations.

Questions and Answers on FINRA’s Eligibility Proceedings for Firms Participating in the Securities and Exchange Commission’s (“SEC” or “Commission”) Share Class Selection Disclosure Initiative (“SCSD Initiative”).

CRCP^® Program Overview

Learn more about the purpose and content of the FINRA Institute at Georgetown CRCP^® program. They include building a culture of compliance and helping compliance professionals take their careers to the next level.

The Underwriter Financial Status Report is a monthly report designed to help firms evaluate the timeliness of financial disclosures made to EMMA, for issuances previously brought to market.   

The purpose of this report is to highlights issuances lacking current audited financial filings (LCF) and the lateness of these missing financial filings, based on their anticipated filing time line.

The report offers two alternate views: