Broker Dealers

FINRA Seeks Feedback on Business Continuity Plans

FINRA is currently seeking feedback on its Business Continuity Rule, including if firms have activated their business continuity plans and whether the costs of creating, maintaining or updating such a plan outweigh the benefits.  Feedback is due April 26, 2019. What makes an effective Business Continuity Plan? An effective plan can create loyal customers by… READ MORE

Communicating Your Clearing Platform Decision

Once you’ve completed your analysis and selected a clearing provider, it’s time to implement the broad communication component of your change management strategy to define how the decision will be delivered and received by your various teams.  Your communication plan should consider all audiences (clients, vendors, sales force, home office, regulators).  There are many appropriate… READ MORE

FINRA Issues FOCUS Report Guidance – Operating Lease Reporting

On March 19, 2019 the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-08, providing guidance on reporting operating lease assets and liabilities on their Focus reports. Background On October 23, 2018, the SEC issued a no action relief letter (the Letter) stating that, absent relief, the right-to-use asset would be a non-allowable asset in… READ MORE

Selecting a Clearing Provider

In our previous blogs we discuss the things you should consider when deciding whether to change clearing platforms. Once you have assessed your needs and determined your firm’s direction around growth, recruiting and technology improvements, it’s time to begin the process of finding the best partner to help achieve your firm’s goals.   Make sure you have projected your business needs far enough into the future (5, 10 or 15… READ MORE

Things to Consider When Selecting a Clearing Partner

Once you complete the preliminary work of analyzing your current business state as described in our previous blog, it’s time to make a decision.  Maybe you have concluded that your current provider will not be able to support your growth plan, or they aren’t engaged in a way that makes financial and operational sense. Regardless,… READ MORE

The Business Case for Evaluating your Clearing Partner

The economic impact to retail broker-dealers of their clearing strategy is larger than ever. Whether deciding between self clearing vs. fully-disclosed, or choosing the best provider when the answer is obvious, a thoughtful analysis and due diligence must be conducted to achieve your best results.  Much is riding on this decision in order to protect your firm… READ MORE

Digital Assets – Where Are We Now?

Last week, JP Morgan announced the launch of “JPM Coin.”  We thought it would be good to recap our posts over the past year on the topic of cryptocurrencies and coin offerings and update you on the current state of this market.   As 2018 began, the market capitalization for cryptocurrencies and other digital assets had reportedly exceeded… READ MORE