In May 2025, FINRA issued a long-anticipated update to its Operations Professional Registration FAQ, clarifying that individuals who post journal entries but lack discretionary authority over capital are not required to register as Series 99 Operations Professionals under Rule 1220(b)(3)(A)(i)c.

ACI executive management has actively engaged with senior FINRA staff on this in recent years, spawning the need for regulatory transparency. For independent broker-dealers, this clarification removes an unnecessary compliance burden and supports the ability to leverage outsourced financial professionals without triggering additional registration requirements.

What This Means for Broker-Dealers

The updated FAQ outlines two common scenarios that clarify how the rule should be interpreted.

1. General Ledger Entry Does Not Require Registration: A general ledger clerk who posts journal entries is not required to register as long as they do not have authority to move funds, commit capital, or enter contracts on behalf of the member firm. The act of recording entries alone, even if significant, does not meet the threshold for registration under Rule 1220(b)(3)(A)(i)c.
   
   
2. Treasury Authority Does Require Registration: A person who can move firm funds without a pre-established materiality limit must register as an Operations Professional. This includes staff with the ability to direct the movement of money or securities, especially when there are no limits based on the firm’s risk management policies or spending guidelines.

How This Plays Out in Practice:

In real terms, this clarification draws a much-needed boundary between operational support and decision-making authority. For firms that outsource ledger entry or back-office accounting, the rule now clearly states that having someone record the numbers isn’t the same as giving them control over the firm’s capital.

It’s the difference between inputting a transaction and having the power to execute it.

Firms no longer need to second-guess whether their external accounting support crosses a regulatory line. That clarity reduces unnecessary oversight costs, removes compliance uncertainty, and allows operations teams to stay focused on accuracy and reporting, without the burden of redundant registration.

Why This Matters to ACI Clients

ACI’s service model has always focused on delivering outsourced accounting and FinOp services in full compliance with FINRA rules. While our staff may post entries and support financial reporting, they do not control firm capital, move money, or bind our clients to contracts.

This distinction has long been a point of regulatory discussion. The recent update affirms that outsourced accounting functions, when properly structured and supervised, fall outside the registration requirement.

ACI’s CEO, Jay Gettenberg, reflected on the decision, “FINRA’s recent clarification on the registration and licensing requirements of back-office support personnel provides our industry with much needed guidance. Registration and licensing requirements have been an area of ambiguity and inconsistent application across regulatory examinations for many years. Authoritative and documented rules allow the industry to better comply and enable its participants to effectively defend their position of compliance with conviction.”

What Broker-Dealers Should Know

• You may outsource accounting and reporting functions without triggering registration, provided those individuals lack discretion over capital.
• Registration is required when individuals have authority to move funds or commit firm resources without defined limits.
• Covered functions still require supervisory oversight from a registered Supervisory Principal.

The full FAQ and supporting guidance is available at: FINRA Operations Professional FAQ.

ACI’s Commitment to Broker-Dealers

ACI remains committed to serving as a trusted partner for broker-dealers navigating regulatory change. This clarification underscores the strength of our model and the importance of smart, compliant outsourcing. Our goal is to reduce complexity, protect our clients from avoidable risk, and provide the expertise needed to operate with confidence.

For questions about this update or how it may impact your supervisory structure, contact our team. We are always here to help.