Broker Dealer Registration Services
ComplianceWorks can address your broker-dealer firm registration needs and concerns. We will work directly with your firm’s managing principal or chief compliance officer to identify registration challenges. We will then build and implement solutions to meet your regulatory responsibilities. We can relieve you of the burden of having to find competent licensing and registration personnel by performing all of your licensing and registration functions for you, or you can start with a few and add services as the need arises.
Conference call with you to discuss your plans for your new business
- Review your firm’s business relationships and types of contractual arrangements needed
- Review FINRA registration types (Introducing, Non-Carrying (Clearing), Prime Broker, etc.).
- Review net capital requirements for each business type
- Review ownership structures designed to minimize the impact on Executives who do not plan to participate in the “day-to-day-operation” of the broker dealer
- Review Representative licensing requirements for each business type
- Review Supervisory Principal licensing requirements based on business type & discuss dual Principal minimum
- Designation of FINRA Executive Representative
- Guidance to help deal with problematic issues where the firm’s application or that of any individual associated with the firm reflects a prior disciplinary or enforcement action
Initial Filing Phase:
- Prepare/Submit “Firm Name Reservation” form to reserve your new firm’s name with FINRA (needed before requesting access to registration filing system),
- Prepare/Submit the CRD SAA Entitlement Form to gain access to the FINRA system
- Prepare/Submit Form BD as the firm’s SEC registration form (requires notarization). There are no further documentation requirements for registration with the SEC.
- Help calculate State registration fees for licensing & registration of representatives and Supervisory Principals
- Preparation of Form U-4 (Uniform Application for Securities Industry Registration or Transfer) for Registered Representatives and Supervisory Principals in each applicable State
Form NMA Filing Phase - New Membership Application: Standards 1 – 12 Questions:
- Provide you with Business Plan template for you to complete that acts as a guide through NMA Standard 1
- Provide you with access to our internal project plan template that acts our guide through NMA Standards 2 – 12
- Setup a full range of ongoing conference calls to execute the New Membership Application (NMA) project plan
Everything we do from this point forward will be to either: (a) answer an NMA Standard question; or (b) respond to follow-up questions from FINRA personnel. CWI controls the input of responses to all NMA Standard questions, but all responses will be a collaborative effort to ensure FINRA gets the specific “business-related” details only you can provide as well as the “compliance” or “regulations” oriented details that we can provide. Going forward, we will meet regularly to check-in on the status of our respective responses and to answer any open questions we might each have. Once we fine-tune each of our responses together, I will input our formal responses into the CRD system.
- CWI to prepare and submit full NMA (Standard 1 -1 2) responses & respond to requests for additional information from FINRA. Below is not an exhaustive list of all Standard requirements.
Standard 1: Overview of the Applicant (Firm)
- Description of business services to be provided
- List of Registered Officers, Directors, etc.
- Supervisory Org Chart
- Company formation documents
Standard 2: Licenses and Registrations
- Description of & relevant experience for Executive Officers, Directors & Supervisory Principals
Standard 3: Compliance with Securities Laws, Just and Equitable Principles of Trade
- Disclosure of issues related to the firm or its Associated Persons in matters of prior disciplinary or enforcement actions
Standard 4: Contractual and Business Relationships
- Disclose proposed contractual or other arrangements and/or business relationships the firm has or will enter into, pertinent to the execution of the proposed business activities.
- Provide sample contracts (related to above)
- Disclose Auditor Information
Standard 5: Facilities
- Describe the adequacy of the firm’s facilities to conduct the proposed business activities
- Disclose co-location tenants (if any)
- Provide deed or lease agreements, etc.
Standard 6: Communications and Operational Systems
- Describe communications and operational systems the firm will employ to conduct business with customers
Standard 7: Maintaining Adequate Net Capital
- Describe nature & source of net capital (terms and conditions of financing (if any))
- Provide bank statements
- Provide pro forma financials & Net Capital Computation worksheet
Standard 8: Financial Controls
- Describe prior work experience of the firm’s FinOp Principal in support of his or her ability to maintain and oversee financial compliance
- Describe financial controls to be employed by the firm
Standard 9: Written Procedures
- Provide customized WSPs (CWI provides for you)
Standard 10: Supervisory Structure
- Provide detailed descriptions for each Supervisor/Principal
Standard 11: Books and Records
- Describe the system for maintaining required books and records
- Describe e-mail retention systems to be employed
Standard 12: Continuing Education
- Provide customized Continuing Education (Firm Element) Needs Assessment (CWI provides)
- Provide one of our experienced and fully licensed CWI personnel to be your Outsourced Chief Compliance Officer as one must be named along with disclosing his/her relevant experience (no minimum time frame required, you can replace with an experienced inhouse CCO at any time)
- Provide you access to our industry relationships with fully licensed FinOps who can provide consultation services related to Net Capital requirements, help you develop proforma financials formatted for initial registration submission, or be your fully licensed outsourced FinOp. Preparation of a Compliance Program including: Written Supervisory Procedures
- Preparation of Business Continuity Plan (FINRA based template)
- Preparation of Continuing Education (Firm Element) Needs Assessment
- Post firm approval, we will provide you with a list of ongoing compliance requirements for your new brokerage firm.
- Provide electronic folder compliance filing system
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