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SEC Request for Comments: Amendments to Rules for Nationally Recognized Statistical Rating Organizations

The Securities and Exchange Commission ("Commission") is proposing amendments to rules for nationally recognized statistical rating organizations ("NRSROs") under the Securities Exchange Act of 1934 ("Exchange Act"). The amendments would provide an exemption from a rule for NRSROs with respect to credit ratings if the issuer of the security or money market instrument referred to … Continue reading SEC Request for Comments: Amendments to Rules for Nationally Recognized Statistical Rating Organizations →

FINRA Requests Comment on Enhancements Under Consideration by the Securities Industry/Regulatory Council on Continuing Education

FINRA requests comment from member firms and other interested parties on enhancements to the Securities Industry Continuing Education Program (CE Program) under consideration by the Securities Industry/Regulatory Council on Continuing Education (CE Council). These enhancements include the transition of the Regulatory Element program to a more focused and shorter learning requirement administered annually. The CE … Continue reading FINRA Requests Comment on Enhancements Under Consideration by the Securities Industry/Regulatory Council on Continuing Education →

FINRA Anti-Money Laundering (AML) Half-Day Seminar – Boca Raton

Boca Raton Marriot 5150 Town Center Circle, Boca Raton, Florida, United States

FINRA’s Anti-Money Laundering (AML) Half-Day Seminars provide attendees with information on the fundamentals of money laundering and money laundering typologies, relevant rules and regulations, and monitoring for suspicious activity. Each seminar provides demonstrations on using data and publicly available information to supplement compliance reviews of exception reports and alerts generated by automated surveillance systems. The … Continue reading FINRA Anti-Money Laundering (AML) Half-Day Seminar – Boca Raton →

2018 FINRA Small Firm Conference

Fairmont Miramar Hotel & Bungalows 101 Wilshire Boulevard, Santa Monica, CA

The  Small Firm Conference focuses on small firms’ practices and tips for complying with FINRA rules. Throughout the event, attendees have the opportunity to discuss small firm issues with FINRA senior staff. Location Fairmont Miramar Hotel & Bungalows, Santa Monica 101 Wilshire Boulevard Santa Monica, CA 90401 Tel: (866) 964-7262 Accommodations A room block has been … Continue reading 2018 FINRA Small Firm Conference →

FINRA Requests Comment on a Proposal to Expand OTC Equity Trading Volume Data Published on FINRA’s Website

FINRA requests comment on a proposal to expand the summary firm data relating to over-the-counter (OTC) equity trading that FINRA publishes on its website by (1) publishing on a one-month delayed basis new monthly aggregate block-size trading data for OTC trades in NMS stocks executed outside an alternative trading system (ATS); (2) publishing aggregate non-ATS … Continue reading FINRA Requests Comment on a Proposal to Expand OTC Equity Trading Volume Data Published on FINRA’s Website →

Outside Brokerage Account Review (FINRA Rule 3270)

The firm should complete the review of the outside brokerage accounts of all associated persons for the prior month. http://finra.complinet.com/en/display/display_main.html?rbid=2403&element_id=3728

SEC Request for Comment: Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers

The Securities and Exchange Commission ("Commission") is reopening the comment period and requesting additional comment (including potential modifications to proposed rule language) on the following: proposed amendments and new rules that would establish capital and margin requirements for security-based swap dealers ("SBSDs") and major security-based swap participants ("MSBSPs") that do not have a prudential regulator, … Continue reading SEC Request for Comment: Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers →

Net Capital Computation (Month ending 10/31/2018)

In accordance with SEC Rule 15c3-1, each broker/dealer registered pursuant to Section 15 of the Act must have evidence of the computation of net capital monthly. That computation should be completed and approved by the FINOP within 17 business days after the end of each month.

Monthly & Fifth FOCUS Part II/IIA Filings (Month ending 10/31/2018)

In accordance with SEC Rule 17a-5(a)(2)(ii)-(iii), each broker/dealer registered pursuant to section 15 of the Act who clears transactions or carries customer accounts shall file Part II of Form X-17 A-5 within 17 business days after the end of the month. The fifth FOCUS filing is required for every broker or dealer who does not carry … Continue reading Monthly & Fifth FOCUS Part II/IIA Filings (Month ending 10/31/2018) →

Outside Business Activity Review (FINRA Rule 3270)

FINRA Rule 3270 prohibits any registered person from being an employee, independent contractor, sole proprietor, officer, director or partner of another person, or being compensated, or having the reasonable expectation of compensation, from another person as a result of any business activity outside the scope of the relationship with the member firm unless he or … Continue reading Outside Business Activity Review (FINRA Rule 3270) →

FINRA Requests Comments: Technology Based Innovations for Regulatory Compliance ( “RegTech”)

FINRA released a white paper outlining recent regulatory technology (RegTech) developments within the securities industry and potential opportunities and implications these technologies may have for broker-dealers. FINRA highlights five areas where industry participants have most prominently leveraged RegTech innovations: surveillance and monitoring, customer identification and antimoney laundering compliance, regulatory intelligence, reporting and risk management and … Continue reading FINRA Requests Comments: Technology Based Innovations for Regulatory Compliance ( “RegTech”) →

SEC Requests Comments: Financial Disclosures about Guarantors and Issuers of Guaranteed Securities and Affiliates Whose Securities Collateralize a Registrant’s Securities

The SEC is proposing amendments to the financial disclosure requirements for guarantors and issuers of guaranteed securities registered or being registered, and issuers’ affiliates whose securities collateralize securities registered or being registered in Regulation S-X to improve those requirements for both investors and registrants. The proposed changes are intended to provide investors with material information given … Continue reading SEC Requests Comments: Financial Disclosures about Guarantors and Issuers of Guaranteed Securities and Affiliates Whose Securities Collateralize a Registrant’s Securities →

FINRA Options Industry Regulatory Conference

During the meeting, FINRA surveillance and examination staff will discuss regulatory priorities and recent findings. To register, please click on the link below and follow the detailed instructions. You will have a choice of attending in person or telephonically; you must register to obtain a dial in phone number.    

National Day of Mourning

FINRA published Information Notice 12/4/18 describing changes to the Contrary Exercise Advice ("CEA," also known as "Expiring Exercise Declaration" or "EED") cut-off time for options that expire on December 5, 2018. As announced by The Options Clearing Corporation (OCC) and the national options exchanges, due to the National Day of Mourning on December 5, 2018, … Continue reading National Day of Mourning →

FINRA New York Region Member Forum

Marriott Marquis 901 Massachusetts Avenue NW, Washington, D.C., DC, United States

The New York Region Member Forum is a half-day event designed to provide financial professionals associated with FINRA member firms in the New York Region the opportunity to engage in key discussions with FINRA New York Regional staff, and connect with industry leaders and peers. The forum also includes thoughtful discussions around the future landscape … Continue reading FINRA New York Region Member Forum →

FINRA Special Election – National Adjudicatory Council

FINRA is conducting a Special Election to fill a Small Firm Vacancy on the National Adjudicatory Council. Petitions for candidacy are due December 13, 2018. Any eligible individual who obtains the requisite number of valid petitions may be included as a candidate on the ballot by following the petition procedures set forth in FINRA Regulation's … Continue reading FINRA Special Election – National Adjudicatory Council →

Outside Brokerage Account Review (FINRA Rule 3270)

The firm should complete the review of the outside brokerage accounts of all associated persons for the prior month. http://finra.complinet.com/en/display/display_main.html?rbid=2403&element_id=3728

Annual Firm Renewals -Deadline on Payments for Preliminary Renewal Statements

Deadline for receipt of Preliminary Statement payments. Firms with sufficient monies in their Flex-Funding Account will have funds automatically transferred to their Renewal Account to cover total renewal fees owed. Transfers will be conducted every day going forward until Web CRD/IARD shuts down for year-end processing December 26.  Failure to remit full payment of their … Continue reading Annual Firm Renewals -Deadline on Payments for Preliminary Renewal Statements →

Preliminary Statement Payment Deadline

DEADLINE for receipt of Preliminary Statement payments. Firms with sufficient monies in their Flex-Funding Account will have funds automatically transferred to their Renewal Account to cover total renewal fees owed. Transfers will be conducted every day going forward until Web CRD/IARD shuts down for year-end processing December 27.  

FINRA Rule 4570 (Custodian of Books & Records) – Proposed Changes – Request for Comment

The SEC requests comment on FINRA's proposal to amend FINRA Rule 4570 (Custodian of Books and Records) to: (1) provide a member that is filing a Form BDW (Uniform Request for Broker-Dealer Withdrawal) the option of designating another FINRA member as the custodian of its books and records on the form; (2) clarify the obligations … Continue reading FINRA Rule 4570 (Custodian of Books & Records) – Proposed Changes – Request for Comment →

Net Capital Computation (Month ending 11/30/2018)

In accordance with SEC Rule 15c3-1, each broker/dealer registered pursuant to Section 15 of the Act must have evidence of the computation of net capital monthly. That computation should be completed and approved by the FINOP within 17 business days after the end of each month.

Monthly & Fifth FOCUS Part II/IIA Filings (month ending 11/30/2018)

In accordance with SEC Rule 17a-5(a)(2)(ii)-(iii), each broker/dealer registered pursuant to section 15 of the Act who clears transactions or carries customer accounts shall file Part II of Form X-17 A-5 within 17 business days after the end of the month. The fifth FOCUS filing is required for every broker or dealer who does not carry … Continue reading Monthly & Fifth FOCUS Part II/IIA Filings (month ending 11/30/2018) →

Outside Business Activity Review (FINRA Rule 3270)

FINRA Rule 3270 prohibits any registered person from being an employee, independent contractor, sole proprietor, officer, director or partner of another person, or being compensated, or having the reasonable expectation of compensation, from another person as a result of any business activity outside the scope of the relationship with the member firm unless he or … Continue reading Outside Business Activity Review (FINRA Rule 3270) →

Review and update Firm Element Continuing Education Plan

FINRA Rule 1250 requires all covered registered persons (any person registered with a member who has direct contact with customers in the conduct of the member's securities sales, trading and investment banking activities, any person registered as an operations professional or research analyst, and to the immediate supervisors of such person) to participate in the … Continue reading Review and update Firm Element Continuing Education Plan →

Annual Audit Filing Due Date (Year Ending October 31, 2018)

SEC Rule 17a-5(d) requires that FINRA member firms to file an Annual Audited Report electronically with FINRA through the firm Gateway and with the SEC (main office and regional office) via mail or overnight carrier not more than 60-calendar days after the date selected for their fiscal year end. The Annual Audit must also be filed with the state regulators (where required). To be a valid filing, the Annual Audit must be physically received by FINRA, the SEC and the state regulators by the due date. (Note: if the Annual Audit cannot be completed by the due date a request for extension to the Annual Audit due date must be made in writing to the FINRA District Office 3 business days prior to the due date).

FINRA Renewal Program – Final Statement Available

Web CRD and IARD are available with complete functionality as of 5 a.m., ET, including submitting form filings and approving registrations. • Overpayments are transferred to firms' Flex-Funding Account. Refund requests should be made from this account through E-Bill. • Final Statements are available for viewing and printing through E-Bill.

Short Interest Reporting Due Date for 12/31/2018

FINRA requires firms to report short interest positions in all customer and proprietary accounts in all equity securities twice a month. Questions Questions regarding the information that firms need to file can be directed to the appropriate District Office. Questions regarding system requirements, file uploads and related submission problems should be directed to (800) 321-6273. Business questions … Continue reading Short Interest Reporting Due Date for 12/31/2018 →

Proposal to Amend FINRA Rules 12214 and 13214 in effect

Proposal to Amend FINRA Rules 12214 and 13214 to Provide That FINRA Will Pay Each Arbitrator a $200 Honorarium to Decide Without a Hearing Session a Contested Subpoena Request or a Contested Order for Production or Appearance Financial Industry Regulatory Authority, Inc. (“FINRA”) is filing with the Securities and Exchange Commission (“SEC” or “Commission”) a … Continue reading Proposal to Amend FINRA Rules 12214 and 13214 in effect →

Customer Margin Balance Report Due – Period ending 12/31/2018

FINRA Rule 4521 requires member firms that carry customer margin accounts to submit debit and credit balances and all securities margin accounts. Customer Margin Balance Reporting and Margin Statistics FINRA Rule 4521 requires that member firms that carry customer margin accounts must submit — via the Customer Margin Balance Form — the following numbers: the total … Continue reading Customer Margin Balance Report Due – Period ending 12/31/2018 →

FINRA Rule 4530/Customer Complaint Filing Due Dates (Q4 2018)

In accordance with FINRA Rule 4530(d), each member shall report to FINRA statistical and summary information regarding customer complaints in such detail as FINRA shall specify by the 15th day of the month following the calendar quarter in which customer complaints are received by the member. For the purposes of this paragraph, "customer" includes any … Continue reading FINRA Rule 4530/Customer Complaint Filing Due Dates (Q4 2018) →

FINRA Rule 4530/Customer Complaint Filing Due Dates (Q4 2018)

In accordance with FINRA Rule 4530(d), each member shall report to FINRA statistical and summary information regarding customer complaints in such detail as FINRA shall specify by the 15th day of the month following the calendar quarter in which customer complaints are received by the member. For the purposes of this paragraph, "customer" includes any … Continue reading FINRA Rule 4530/Customer Complaint Filing Due Dates (Q4 2018) →

2019 FINRA RegTech Conference

InterContinental New York Times Square 300 West 44th Street, New York, United States

Regulation is a fundamental pillar of the financial services industry, ensuring investor protection and market integrity. As financial services firms seek to comply with regulatory requirements, they are turning to new and innovative regulatory technology (RegTech) tools to assist them in effectively and efficiently meeting their obligations. While RegTech tools may help strengthen firms’ compliance … Continue reading 2019 FINRA RegTech Conference →

Outside Brokerage Account Review (FINRA Rule 3270)

The firm should complete the review of the outside brokerage accounts of all associated persons for the prior month. http://finra.complinet.com/en/display/display_main.html?rbid=2403&element_id=3728

Martin Luther King, Jr. Day – Market Holiday

FINRA operates Monday - Friday during regular business hours.  FINRA is closed whenever the markets are closed.  In addition, FINRA and financial markets may close early the day before a holiday.   http://www.finra.org/AboutFINRA/HolidaySchedule

FINRA Renewal Program – Final Statement Payment Deadline

DEADLINE for receipt of Final Statement payments. Firms with sufficient monies in their Flex- Funding Account will have funds automatically transferred to their Renewal Account to cover total renewal fees owed. Transfers will be conducted every day until any outstanding renewal assessment is satisfied.  

FINRA Contact System Review

FCS facilitates member firm reporting of key contacts to FINRA, which is a requirement of FINRA rules and By-Laws. Designated firm contacts are used to facilitate voting in FINRA elections, compliance with various rules and By-Laws, and to improve FINRA's communication with our member firms. FINRA Rule 4517 requires firms to: update all contact information … Continue reading FINRA Contact System Review →

Outside Business Activities Review

FINRA Rule 3270 prohibits any registered person from being an employee, independent contractor, sole proprietor, officer, director or partner of another person, or being compensated, or having the reasonable expectation of compensation, from another person as a result of any business activity outside the scope of the relationship with the member firm unless he or … Continue reading Outside Business Activities Review →

Annual FCS Reporting for 2019

FINRA broker/dealers must appoint and certify to FINRA one executive representative to represent, vote, and act on behalf of the broker/dealer in all affairs of FINRA. The executive representative must be a member of senior management and a registered principal of the firm. In addition, the executive representative is required to maintain an Internet electronic … Continue reading Annual FCS Reporting for 2019 →

Annual Firm Filing and Contact Reporting for 2019

FINRA broker/dealers must appoint and certify to FINRA one executive representative to represent, vote, and act on behalf of the broker/dealer in all affairs of FINRA. The executive representative must be a member of senior management and a registered principal of the firm. In addition, the executive representative is required to maintain an Internet electronic … Continue reading Annual Firm Filing and Contact Reporting for 2019 →

Quarterly FOCUS Part llA Filings (Quarter ending 12/31/2018)

In accordance with SEC Rule 17a-5(a)(2)(iii), each broker/dealer registered pursuant to section 15 of the Act who does not carry nor clear transactions nor carry customer accounts shall file Part IIA of Form X-17 A-5 within 17 business days after the end of each calendar quarter. taft.law.uc.edu/CCL/34ActRls/rule17a-5.html

MSRB Update of Primary Contact Information (MSRB G-40)

MSRB Rule G-40 requires all municipal securities dealers and municipal advisors with an MSRB account to update their primary contact information or affirm that the information is correct within 17 business days after the end of each calendar year. In addition to this annual requirement, MSRB Rule G-40 requires municipal securities dealers and municipal advisors … Continue reading MSRB Update of Primary Contact Information (MSRB G-40) →

Monthly & Fifth FOCUS IIA Filings (Month ending 12/31/2018)

In accordance with SEC Rule 17a-5(a)(2)(ii)-(iii), each broker/dealer registered pursuant to section 15 of the Act who clears transactions or carries customer accounts shall file Part II of Form X-17 A-5 within 17 business days after the end of the month. The fifth FOCUS filing is required for every broker or dealer who does not carry … Continue reading Monthly & Fifth FOCUS IIA Filings (Month ending 12/31/2018) →

Net Capital Computation (Month ending 12/31/2018)

In accordance with SEC Rule 15c3-1, each broker/dealer registered pursuant to Section 15 of the Act must have evidence of the computation of net capital monthly. That computation should be completed and approved by the FINOP within 17 business days after the end of each month.

Disclosure of Order Routing Practices (SEC Rule 606) (Q4 2018)

SEC Rule 606 requires broker/dealers that route orders on behalf of customers to prepare quarterly reports that disclose the identity of the venues to which it routed orders for execution. The reports also will disclose the nature of the broker-dealers relationship with those venues, including the existence of any internalization or payment for order flow … Continue reading Disclosure of Order Routing Practices (SEC Rule 606) (Q4 2018) →

Quarterly SSOI Supplemental FOCUS Information (Quarter ending 12/31/2018)

FINRA Rule 4524 requires each member firm to file a Supplemental Statement of Income (“SSOI”) within 20 business days after the end of each calendar quarter via the FINRA Gateway. The SSOI is designed to provide FINRA with greater detail regarding firm’s revenue and expenses. finra.complinet.com/en/display/display.html

2019 Compliance Outreach Program for Municipal Advisors

Hyatt Regency San Francisco 5 Embarcadero Center, San Francisco, CA, United States

The Compliance Outreach Program for Municipal Advisors is a free one-day program designed to provide an open forum for municipal advisory industry professionals to discuss current compliance practices with regulators and promote a more effective compliance structure for regulatory obligations of municipal advisors. The program is sponsored by the SEC’s Office of Compliance Inspections and … Continue reading 2019 Compliance Outreach Program for Municipal Advisors →

Outside Brokerage Account Review (FINRA Rule 3270)

The firm should complete the review of the outside brokerage accounts of all associated persons for the prior month. http://finra.complinet.com/en/display/display_main.html?rbid=2403&element_id=3728

Presidents’ Day – Market Holiday

FINRA operates Monday - Friday during regular business hours.  FINRA is closed whenever the markets are closed.  In addition, FINRA and financial markets may close early the day before a holiday.   http://www.finra.org/AboutFINRA/HolidaySchedule

Outside Business Activity Review (FINRA Rule 3270)

FINRA Rule 3270 prohibits any registered person from being an employee, independent contractor, sole proprietor, officer, director or partner of another person, or being compensated, or having the reasonable expectation of compensation, from another person as a result of any business activity outside the scope of the relationship with the member firm unless he or … Continue reading Outside Business Activity Review (FINRA Rule 3270) →

Monthly & Fifth FOCUS II/IIA Filings(month ending 01/31/2019)

In accordance with SEC Rule 17a-5(a)(2)(ii)-(iii), each broker/dealer registered pursuant to section 15 of the Act who clears transactions or carries customer accounts shall file Part II of Form X-17 A-5 within 17 business days after the end of the month. The fifth FOCUS filing is required for every broker or dealer who does not carry … Continue reading Monthly & Fifth FOCUS II/IIA Filings(month ending 01/31/2019) →

Net Capital Computation (Month ending 01/31/2019)

In accordance with SEC Rule 15c3-1, each broker/dealer registered pursuant to Section 15 of the Act must have evidence of the computation of net capital monthly. That computation should be completed and approved by the FINOP within 17 business days after the end of each month.

FINRA Board of Governors Meeting – February/March 2019

FINRA’s Board of Governors met on Feb. 28 and March 1 in Boca Raton, Florida, where it discussed the organization’s finances, reviewed several significant technology and other capital initiatives, and considered two rulemaking items (described below). The Board also met with staff from FINRA’s Boca Raton District Office, home of the FINRA Securities Helpline for Seniors and … Continue reading FINRA Board of Governors Meeting – February/March 2019 →

Supplemental Inventory Schedule (report period ended 01/31/2019)

The Supplemental Inventory Schedule (SIS) must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, unless the firm has (1) a minimum dollar net capital or liquid capital requirement of less than $100,000; or (2) inventory positions consisting only of money market mutual funds.6 A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

FINRA Podcast – Member Relations & Education: Making Regulation Smarter

As a self-regulatory organization, FINRA is uniquely positioned to gain meaningful insights from its members to help ensure FINRA’s regulatory programs are working for everyone. Tasked with maintaining that relationship and keeping an open dialogue is FINRA’s Office of Member Relations and Education. The Member Relations and Education team routinely engages with firms through conferences, … Continue reading FINRA Podcast – Member Relations & Education: Making Regulation Smarter →

SIFMA’s Compliance And Legal Society Annual Seminar

JW Marriot Phoenix Desert Ridge 5350 East Marriot Drive, Phoenix, Arizona

Stephanie Avakian and Steven Peikin, Co-Directors of the Division of Enforcement, will participate in a panel at SIFMA’s Compliance and Legal Society Annual Seminar. Agenda details.

Net Capital Computation (Month ending 02/28/2019)

In accordance with SEC Rule 15c3-1, each broker/dealer registered pursuant to Section 15 of the Act must have evidence of the computation of net capital monthly. That computation should be completed and approved by the FINOP within 17 business days after the end of each month.

Outside Business Activity Review (FINRA Rule 3270)

FINRA Rule 3270 prohibits any registered person from being an employee, independent contractor, sole proprietor, officer, director or partner of another person, or being compensated, or having the reasonable expectation of compensation, from another person as a result of any business activity outside the scope of the relationship with the member firm unless he or … Continue reading Outside Business Activity Review (FINRA Rule 3270) →

Review and Update Firm Element Continuing Education Plan

FINRA Rule 1250 requires all covered registered persons (any person registered with a member who has direct contact with customers in the conduct of the member's securities sales, trading and investment banking activities, any person registered as an operations professional or research analyst, and to the immediate supervisors of such person) to participate in the … Continue reading Review and Update Firm Element Continuing Education Plan →

Annual Attestation for Research Supervisory Procedures NASD Rule 2711(i)

NASD Rule 2711(i) requires that a senior officer of the broker-dealer attest annually to FINRA electronically through the firm Gateway that the broker-dealer has adopted and implemented written supervisory procedures that are reasonably designed to achieve compliance with the rule's provisions and that the compensation of all research analysts was reviewed and approved and the … Continue reading Annual Attestation for Research Supervisory Procedures NASD Rule 2711(i) →

FINRA Rule 4530/Customer Complaint Filing Due Dates (Q1 2019)

In accordance with FINRA Rule 4530(d), each member shall report to FINRA statistical and summary information regarding customer complaints in such detail as FINRA shall specify by the 15th day of the month following the calendar quarter in which customer complaints are received by the member. For the purposes of this paragraph, "customer" includes any … Continue reading FINRA Rule 4530/Customer Complaint Filing Due Dates (Q1 2019) →

FINRA Rule 4530/Customer Complaint Filing Due Dates (Q1 2019)

In accordance with FINRA Rule 4530(d), each member shall report to FINRA statistical and summary information regarding customer complaints in such detail as FINRA shall specify by the 15th day of the month following the calendar quarter in which customer complaints are received by the member. For the purposes of this paragraph, "customer" includes any … Continue reading FINRA Rule 4530/Customer Complaint Filing Due Dates (Q1 2019) →

Quarterly FOCUS Part llA Filings (Quarter ending 3/31/2019)

In accordance with SEC Rule 17a-5(a)(2)(iii), each broker/dealer registered pursuant to section 15 of the Act who does not carry nor clear transactions nor carry customer accounts shall file Part IIA of Form X-17 A-5 within 17 business days after the end of each calendar quarter.

Quarterly FOCUS Part llA Filings (Quarter ending 03/31/2019)

In accordance with SEC Rule 17a-5(a)(2)(iii), each broker/dealer registered pursuant to section 15 of the Act who does not carry nor clear transactions nor carry customer accounts shall file Part IIA of Form X-17 A-5 within 17 business days after the end of each calendar quarter.

Supplemental Inventory Schedule (report period ended 3/31/2019)

The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report
Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS
reporting period, unless the firm has (1) a minimum dollar net capital or liquid capital
requirement of less than $100,000; or (2) inventory positions consisting only of money
market mutual funds.6 A firm with inventory positions consisting only of money market
mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

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