Important Reminders

Presented By: Laura Crosby-Brown

Renewals  - The annual renewal process for broker-dealer and investment advisors will begin again in November. Some important dates in the calendar are as follows:

Regulatory Compliance will be providing copies of information regarding where the firm and its representatives are registered, preliminary renewal statements and payment reminders to our Compliance Partner and FINOP clients, and will assist these firms with any registration filings.

Annual Audit – The due date by which annual audit reports must be received by FINRA and the SEC are as follows:

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:

Keep in mind that if your company’s year–end is October 31, 2009 or November 30, 2009 and you are usually a quarterly FOCUS filer, you have a Fifth FOCUS due on November 24 or December 23, 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 October 30, 2009 for the quarter ending September 30, 2009. Log onto www.msrb.org for more information.

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 1/4 of 1% of their annual net operating revenues, assessed semi-annually. 

Firms that have a fiscal year end April 30, 2009 or after 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:

Firms that had a fiscal year-end between October 31, 2008 and April 1, 2009 will be required to calculate their 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 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:

Holidays –

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