Frequently Asked Questions
GENERAL QUESTIONS
1. What type of experience will ACI bring to my firm?
ACI has over 25 years of experience in providing high quality consulting and financial services. Our consulting staff includes former SEC Regulators, JDs, Chief Compliance Officers, AML Auditors, FINOPs, and Certified Public Accountants. Amongst our staff we hold the Series 3, 4, 7, 24, 27, 28, 53, 55, 66, 79.
2. How has ACI been recognized as a leader in regulatory compliance and accounting services?
ACI's consultants are well-regarded by some of the most respected news media and trade organizations. Our senior staff has been quoted in industry leading publications such as The Wall Street Journal and Investment News and has spoken at major trade conferences such as FINRA, NSCP, NAIBD, FSX and Jefferies.
To view press mentions visit www.acisecure.com/press.
For ACI's regulatory and accounting insights visit www.acisecure.com/blog.
To view our upcoming speaking engagements visit www.acisecure.com/events.
3. I bought a Broker Dealer Firm, now what do I do?
The following checklist is a general Q&A guideline designed to assist firms involved in an organizational change such as a merger, acquisition or succession. The items suggest possible FINRA-related steps and questions a firm should consider.
ACCOUNTING QUESTIONS
1. What is the benefit of outsourcing accounting services?
The greatest value provided by outsourcing accounting services is the ability to engage a well-trained professional while incurring only a fraction of the cost of hiring a full-time consultant.
2. How does ACI price its accounting services?
Our prices are not based upon size or profitability of the clients we service. The most definitive measure in determining our pricing structure is the transactional volume incurred each month.
3. Can ACI service financial services clients not located in New York?
While ACI is based in Manhattan’s financial district, there is no geographical limitation to the accounting services we can provide to our clients. Electronic communication has allowed us to offer remote clients with the same quality of service that is provided to regional firms. We are able to gather documents directly from the third party providers and can also provide remote online access so clients can constantly view the financial activities of their respective firms.
4. Does ACI fulfill FINRA’s licensing requirements?
ACI will provide each client with a Series 27 licensed accountant to act in the capacity of Financial & Operations Principal. The FINOP will be responsible for overseeing the firm’s financial operations and will sign the FOCUS Report as validation of the accuracy of the information provided to FINRA.
5. How do auditors conduct their audits when ACI prepares the books and records?
ACI’s headquarters serve as the location of the financial books and records for our clients. Our accountants are typically more familiar with the financial well-being and net capital than the owners of the firms we service. For this reason, our accountants provide the assistance required to conduct the audit in the most timely and efficient manner.
6. How does FINRA conduct its financial examination?
Much as is the case with year-end audits, FINRA relies on ACI’s access to financial information to help facilitate their examinations. Assisting FINRA during their examination prevents our clients from focusing on their core competencies. By providing the regulators with necessary documentation and insight, ACI is able to shorten the length of the examination and limit the likelihood of financial findings and regulatory fines.
7. Does ACI conduct year-end audits?
ACI is prohibited from providing year-end audits for independence reasons. The year-end audit is conducted with the purpose of providing independent third party verification of the accuracy of the broker dealer’s books and records. As the preparer of books and records, ACI is not considered independent because we would be reviewing our own work product.
8. Who has access to my books and records?
Client books and records contain confidential information and are treated in that manner. Only ACI employees, FINRA examiners, hired auditors and the clients themselves will have access to internal accounting information.
COMPLIANCE QUESTIONS
1. Does ACI serve as my firm's CCO?
ACI suggests that your firm's CCO be a staff member within your firm, even if the individual is also (and likely will be) serving a dual function. We suggest that the CCO be at the firm so he or she can monitor day to day transactions and ensure the implementation of the compliance program. ACI does not serve as the CCO; however, we provide CCO training and placement services to ensure that you have a qualified professional to fill the role. We then work with your CCO to develop, submit, and maintain all required compliance documentations and serve as your CCO's consultant and compliance team.
2. If I already have an internal compliance program, can I utilize ACI's services?
Absolutely. Regulators and investors are increasingly skeptical of firms that perform all financial and regulatory oversight in-house. Hiring a reputable third-party consultant will increase investor confidence in your firm and provide a fresh perspective when reviewing documentations and controls. Bringing in a third-party consultant to review your internal operations will increase the likelihood that your compliance efforts are sound and will pass an SEC or FINRA exam. One of ACI's most popular services for clients with an existing compliance infrastructure is our Mock SEC Audit. ACI's mock audit is an on-site sampling of your firm's compliance documents, procedures and controls. Mock audits are designed to replicate the audit conducted by FINRA or the SEC and to prevent regulatory findings.
3. What do I get as part of my monthly compliance consulting?
ACI can provide monthly compliance consulting to keep your firm informed of the latest regulations and answer any compliance questions or concerns that arise within your firm. Our clients receive unlimited phone access to our regulatory experts for compliance consulting questions for a set monthly fee.
4. Do I need a customized compliance manual or will a boiler-plate manual do?
Your firm is required by law to craft and edit supervisory procedures. Every regulatory examiner can spot a “canned” boiler-plate manual. ACI has evaluated the major publishers of procedures and only recommends those that pass our rigorous standards. After selecting a procedures manual, ACI will assist you in tailoring your manual so it effectively describes your firm's processes and risks.
