New SIPC Assessment – Effective April 1, 2009, SIPC changed its assessment and required payment procedures. Broker-dealers are now required to pay an assessment equal to one quarter of 1% of their annual net operating revenues, assessed semi-annually.
For firms with a fiscal year-end April 30, 2009 or after, you will need to complete the SIPC-7T Transitional Assessment Reconciliation. The form will be mailed to the firm by SIPC at the end of the firm’s year-end. It must be complete and returned to SIPC with the applicable payment within 60 days of the end of the firm’s fiscal year. Due dates are as follows:
Year-end Date
June 30, 2009
July 31, 2009
August 31, 2009
September 30, 2009
October 31, 2009 |
Reporting Period
April 1 through June 30, 2009
April 1 through July 31, 2009
April 1 through August 31, 2009
April 1 through September 30, 2009
April 1 through October 31, 2009 |
Due Date
August 31, 2009
September 29, 2009
October 30, 2009
November 30, 2009
December 30, 2009 |
For firms that had a fiscal year-end between October 31, 2008 and April 1, 2009, you will be required to calculate your first assessment using the SIPC-6 General Assessment Payment Form. This form calculates the payment due on net operating revenues for the six months following end of the firm’s fiscal year. SIPC will mail forms to firms at the end of the six-month period. The form and assessment will be due within 30 days of this six-month date. However, since the new assessment was not effective until April 1, firms with a fiscal year-end prior to the date will pro-rate their revenues to report only the applicable period after April 1. Due dates and reporting periods are as follows:
Year-end Date
January 31, 2009
February 28, 2009
March 31, 2009 |
Reporting Period
April 1 through July 31, 2009
April 1 through August 31, 2009
April 1 through September 30, 2009 |
Due Date
August 31, 2009
September 30, 2009
October 30, 2009 |
Annual Audit – The due date by which annual audit reports must be received by FINRA and the SEC are as follows:
Year-end Date
June 30, 2009
July 31, 2009
August 31, 2009
September 30, 2009 |
Due Date
August 31, 2009
September 29, 2009
October 30, 2009
November 30, 2009 |
Note – Don’t forget to send a report to any states in which you are registered that require filing by the due date.
Auditors - Effective January 1, 2009, all audits for broker-dealers need to be completed by a PCAOB member auditor. You can verify whether or not your auditor is a member by visiting www.pcaob.org. If your auditor is not a member, you will need to engage a new auditor to perform your audit for this and future years and will need to file a change of auditor notification through FINRA’s electronic notification system.
Focus Filings – Focus filing dates for the next three months are as follows:
If you file:
Monthly
Monthly
Monthly/Quarterly
|
Period
July 2009
August 2009
September 2009 |
Due Date
August 25, 2009
September 24, 2009
October 23, 2009 |
Keep in mind that if your company’s year-end is July 31, 2009 or August 31, 2009 and you are normally a quarterly FOCUS filer, you have a fifth FOCUS due on August 25 or September 24, respectively.
MSRB G37/G38 Filings - If you are an MSRB member and are required to file a G37 or G38 to report Political Contributions, the filing due date is October 30, 2009 for the quarter ending September 30, 2009. Log onto www.msrb.org for more information.
3070 Reporting – If you have customer complaints that require reporting under Rule 3070 for the quarter ending September 30, 2009, these reports must be completed by October 15, 2009.
Holidays –
September 7 |
Stock and bond markets and Regulatory Compliance will be closed
for Labor Day. |
October 12 |
Bond markets and banks will be closed for Columbus Day. |
November 11 |
Bond markets and banks will be closed for Veterans Day. |
November 26 |
Stock and bond markets and Regulatory Compliance will be closed
for Thanksgiving. |
November 27 |
Stock markets are scheduled to close at 1pm.
Bond markets are scheduled to close at 2pm.
Regulatory Compliance will be closed. |
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