Regulatory Obligations and Related Considerations
Regulatory Obligations
Exchange Act Rule 15c3-1 (Net Capital Rule) requires that firms must at all times have and maintain net capital at specific levels to protect customers and creditors from monetary losses that can occur when firms fail. Exchange Act Rule 17a-11 requires firms to notify FINRA in the event their net capital falls below the “
Regulatory Obligations and Related Considerations
Regulatory Obligations
Effective liquidity controls are critical elements in a broker-dealer’s risk management framework. Exchange Act Rule 17a-3(a)(23) requires firms that meet the thresholds specified under the rule to make and keep current records documenting the credit, market, and liquidity risk management controls established and
Regulatory Obligations and Related Considerations
Regulatory Obligations
Under the financial responsibility rules, and related supervisory obligations, firms need to properly capture, measure, aggregate, manage and report credit risk, including risk exposures that may not be readily apparent. Such responsibility can be incurred under clearing arrangements, prime brokerage arrangements (
NASD would like to thank the committee for the invitation to submit this written statement for the record in support of H.R. 2179, the Securities Fraud Deterrence and Investor Restitution Act.
Summary
FINRA has adopted amendments to Rule 2231 (Customer Account Statements) to add eight new supplementary materials pertaining to:
compliance with Rule 4311 (Carrying Agreements);
the transmission of customer account statements to other persons or entities;
the use of electronic media to satisfy delivery obligations;
compliance with Rule 3150 (Holding of Customer Mail);
the
Exemptive relief is granted based on the following considerations: the Contribution was made by an individual who, at of the time of the Contribution, had never been an MFP nor was Name involved in the Firm’s municipal securities business. We believe the possibility that the payment was intended to influence issuer officials is significantly minimized. To the extent that any potential investor protection concerns exist, the staff believes these concerns will be appropriately addressed by the Firm’s existing firewall procedures for Name.
Application of registration and supervisory requirements to certain activities conducted by a member firm in the U.S. relating to sales outside the U.S. of foreign mutual funds.
SUGGESTED ROUTING*
Senior Management Government SecuritiesLegal & Compliance OperationsTrading
*These are suggested departments only. Others may be appropriate for your firm.
EXECUTIVE SUMMARY
On November 2, 1988, the Securities and Exchange Commission approved amendments to the NASD By-Laws and Rules of Fair practice and new Government Securities Rules designed to permit the NASD
In June 2007, FINRA (then NASD and NYSE Member Regulation)1 issued for comment proposed guidance regarding the review and supervision of electronic communications. FINRA received 16 comment letters, with a majority of commenters supporting the guidance.
Remarks From the SIFMA Compliance and Legal Division's Annual Seminar
