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 whose fiscal year end is 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 completed 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
April 30, 2009
May 31, 2009
June 30, 2009
July 31, 2009
August 31, 2009
September 30, 2009 |
Reporting Period
April 1 through April 30, 2009
April 1 through May 31, 2009
April 1 through June 30, 2009
April 1 through July 31, 2009
April 1 through August 31, 2009
April 1 through September 30, 2009
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Due Date
June 30, 2009
July 30, 2009
August 31, 2009
September 29, 2009
October 31, 2009
November 30, 2009
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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 the 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 6-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
October 31, 2008
November 30, 2008
December 31, 2009
January 31, 2009
February 28, 2009
March 31, 2009
|
Reporting Period
April 1 through April 30, 2009
April 1 though May 31, 2009
April 1 through June 30, 2009
April 1 through July 31, 2009
April 1 through August 31, 2009
April 1 through September 30, 2009 |
Due Date
June 1, 2009
June 30, 2009
July 30, 2009
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
May 31, 2009
June 30, 2009
July 31, 2009
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Due Date
July 30, 2009
August 31, 2009
September 29, 2009
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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
Quarterly/Monthly
Monthly
|
Period
May 2009
June 2009
July 2009 |
Due Date
June 23, 2009
July 24, 2009
August 25, 2009 |
Keep in mind that if your company’s year–end is May 31, 2009 or July 31, 2009 and you are normally a quarterly FOCUS filer, you have a Fifth FOCUS due on June 23 or August 25, respectively.
MSRB G37/G38 Filings - If you are a MSRB member and are required to file a G37 or G38 to report Political Contributions, the filing due date is July 31, 2009 for the quarter ending June 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 June 30, 2009, these reports must be completed by July 15, 2009.
Holidays –
May 25 The Markets and Regulatory Compliance will be closed for
Memorial Day
July 3 The Markets and Regulatory Compliance will be closed for
Independence Day.
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