FINRA just clarified a question that has been a thorn in the side for many outsourced FINOPs and their broker-dealer clients for many years: Are FINOPs required to make on-site inspections of their clients’ records to fulfill their regulatory duties?
The short answer: No.
The SEC recently provided non-carrying broker dealers with an alternative option as to how they can maintain their exemptive status under SEC Rule 15c-3-3.
ACI Managing Partner, Jay Gettenberg, has worked closely with the Public Company Accounting Oversight Board (PCAOB) and FINRA in recent years to address the practical reality that there are FINRA member firms who do not hold customer funds, yet do not technically qualify under any of the four exemptions listed on the X-17A-5 Focus Report.
ACI Managing Partner, Jay Gettenberg, will participate in a broker-dealer update tech session teleconference on July 30, 2020 to discuss the regulatory accounting and auditing issues that arose from the coronavirus pandemic.
The six-person panel, “Accounting and Auditing in COVID Times,” sponsored by the Foundation for Accounting Education, will examine how the pandemic affected industry practices. ACI’s focus during this panel will be to share practical lessons learned while helping over 50 broker-dealer clients navigate the SBA-backed Paycheck Protection Program.
Like many of you, ACI has been weighing when to return to the office as New York City approaches Phase 3.
Our original plan was to implement a partial return on July 6th. After discussing amongst our staff and weighing the consequences, we have decided to hold off until at least September.