Important Reminders

Presented By: Laura Crosby-Brown

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: 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.

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. 

SIPC-7T - Firms that have a fiscal year end of 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.

Note: A Supplemental SIPC Report must be included with your annual audit that is submitted to FINRA and the SEC.

SIPC-6 – The SIPC-6 is the semi-annual reporting form that firms must file with 30 days of the midpoint of the fiscal year. This form is mailed to firms by SIPC and includes income from the period beginning on the first day of the fiscal year and ending 6 months later.

Focus Filings – Focus filing dates for the next three months are as follows:

Keep in mind that if your company’s year–end is January 31, 2010 or February 28, 2010 and you are usually a quarterly FOCUS filer, you have a Fifth FOCUS due on February 24 or March 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 April 30, 2010 for the quarter ending March 31, 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 March 31, 2010, these reports must be completed by April 15, 2010.

Holidays –

3012 Testing & Verification – You are required to test and verify your supervisory procedures and present a report to senior management within one year of the anniversary of your previous report. For firms that have a due date between now and April 1, 2010, now is the time to start planning for this and to document any testing you have done during 2009.

3130 Certification – The senior business officer of each broker-dealer is required to sign the annual CEO certification (required language found in FINRA Rule 3130) on or before the anniversary of his/her signature of the previous certification.

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