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-7 – The SIPC-7 is the annual reconciliation reporting form that firms must file within 60 days of their fiscal year-end. The due date by which the SIPC – 7 and any applicable payment must be received by SIPC are as follows:

Note - A Supplemental SIPC Report may be required to 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 firm by SIPC and includes income from the period beginning on the first day of the fiscal year and ending six months later.

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

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 30, 2010 for the quarter ending June 30, 2010. 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, 2010, these reports must be completed by July 15, 2010.

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 August 1, 2010, now is the time to start planning for this and to document any testing you have done since your last testing was completed in 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.

RIA Annual Amendments - Investment advisers are required to file an amendment to update their Form ADV annually within 90 days of their year-end. Due dates by which these annual amendments are due are as follows:

Holidays –

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