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Broker-Dealer Services

Most small and mid-size firms cannot carry a full-time general counsel and a full-time compliance officer. This practice exists for them.

The New York Stock Exchange facade lit at night

The practice

More than defense.

The firm was founded by a former president, chief executive and chief compliance officer of a FINRA member broker-dealer — someone who took a firm through the new member application under Rule 1014 and wrote its entire supervisory system before ever advising anyone else on theirs.

That shapes how this practice works. Defending an examination finding is the expensive end of the problem. The cheaper end is the business planning that happens first: how a new product line changes the supervisory obligation, whether a proposed compensation arrangement survives contact with the rules, what a change in ownership will require before it is agreed rather than after.

For some firms the arrangement is standing rather than occasional — acting as external general counsel and compliance department, from the initial application through routine reviews. For others it is a single application, one examination, or one complaint. Companies outside the securities industry are served by a separate practice.

Services

Across the life of the firm.

  • Formation and registration
  • New member application — Rule 1014
  • Continuing membership — Rule 1017
  • Regulatory inquiry and exam assistance
  • Internal investigations
  • Risk assessments
  • Customer complaint response
  • Product due diligence
  • Written supervisory procedures
  • Branch and representative reviews
  • Order handling review
  • Compliance department audits
  • Trading compliance
  • Training and continuing compliance
  • Operations and marketing reviews
  • Form BD and membership agreement amendments
  • Regulation Best Interest policies
  • Communications with the public — Rule 2210
  • Supervisory control procedures — Rules 3120 and 3130
  • Books and records — Rule 17a-4
  • Off-channel communications and retention
  • Cybersecurity and Regulation S-P
  • Business continuity planning
  • Outside business activity review
  • Private securities transaction review
  • Form U4 and U5 disclosure
  • Branch office registration
  • Annual compliance meeting
  • Continuing education programs
  • Senior and vulnerable investor procedures
  • Net capital and financial responsibility coordination

Interested in our services?

We would appreciate hearing from you.

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