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Anti-Money Laundering and Correspondent Accounts
Correspondent accounts are defined by the USA PATRIOT Act as “an account established to receive deposits from, make payments on behalf of a foreign financial institution, or handle other financial transactions related to such institution.” It is important to note that one of the exclusions from this definition is an account handled by an executing broker in a prime brokerage arrangement.... |
By: Nathan Jodat |
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FINRA 2010 Field Examinations
In keeping with our practice of providing information on FINRA-announced priorities for its annual cycles of field examinations of member firms, the following summary of FINRA’s March 1, 2010 release (the “Release”) describes the concerns and areas of concentration that FINRA intends to incorporate in this year’s field examinations. Not surprisingly, a number of the concerns appear to be prompted by... |
By: Sy Bucholz of Garvey Schubert Barer |
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FINRA Contact System and Key Contacts
NASD Rule 1160 requires FINRA member firms to update contact information in the FINRA Contacts System (FCS) within 30 days following any changes, and to review required contact information annually. We often receive questions concerning the FCS, which roles require the designated individual to be registered with the member firm, which roles require the designated individual to be a principal of the firm... |
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Financial Regulatory Reform – What Does it Mean for You?
Broker-dealers and financial advisers may well be concerned about the potential effects on their business that may come from the financial regulatory reform proposals now before the U.S. Senate. This article identifies some aspects of the proposed legislation that are of importance to broker-dealers and investment advisers. The author is indebted to a more comprehensive... |
By: Geoffrey T. Chalmers, Esq.
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