Monday, October 8, 2007

Anti-money Laundering

Anti-money laundering is a continuously evolving issue that places additional due diligence and reporting responsibilities on firms, supervisors, and registered representatives.

Section 352 of the USA PATRIOT ACT amended the BSA to require financial institutions to establish an AML program, report suspicious activity, verify the identity of customers and apply due diligence in all matters especially to accounts involving foreign persons.

Broker-dealers can meet this requirement by maintaining an AML compliance program that complies with SRO rule requirements. NASD Rule 3011 and NYSE Rule 445 require their member organizations to establish risk-based AML compliance programs.

Thursday, October 4, 2007

FINRA Requesting Feedback on Proposed Amendments to OTC Trade Reporting Requirements for Equity Securities

Regulatory Notice 07-46

Comment Period Expires November 12, 2007

FINRA is soliciting feedback from member firms and other interested parties on two proposals relating to OTC trade reporting requirements applicable to listed and unlisted equity securities.

Trade Reporting Structure Proposal: FINRA is proposing to simplify and update the current market maker-based trade reporting structure and is seeking comment on alternative structures.

Linking Proposal: FINRA is proposing to require firms to provide information sufficient to link tape and non-tape reports that are submitted to FINRA for the same overall transaction.

To view the full Notice click here.

FINRA Introduces “Batch Submission” for Advertising Regulation Electronic Files (AREF)

Effective October 29, 2007

FINRA announces the availability of “Batch Submission”. Firms that file a very large volume of communications (typically around 500 per year or more) may wish to consider using the new Batch Submission process.

Effective October 29, 2007, firms will be required to provide further regulatory data about each AREF submission. This new data will help the Department prioritize firm submissions. Also on October 29, 2007, AREF will be enhanced to enable firms to provide additional information like rankings back up data and cover letters at the time they initially upload communications for review.


To view Regulatory Filing Applications click here.
To view more on advertising regulation information click here.
To view more information on “Batch Submissions” click here.
To learn more about regulatory data requirements click here.
If you have entitlement to use AREF and would like to view pending changes to the system click here.