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

Former FTB Advisors CCO Joins Oyster Consulting

  Oyster responds to industry need for operations and compliance experts   Nikki Brinkerhoff recently joined Oyster Consulting as an Associate Director, expanding Oyster’s Operations and Compliance practices. The move increases the firm’s ability to help industry members optimize operations and compliance functions, as well as design and implement technology solutions to improve operational excellence, improve… READ MORE

Reg BI Article Published by Oyster Director Evan Rosser

In April 2018, the SEC presented its long awaited rule proposal Regulation Best Interest (“Reg BI”) as a three-part regulatory package aimed at reforming the way that investment professionals serve retail investors. If enacted as proposed, Reg BI would impose upon broker-dealers an obligation to act in a retail customer’s “best interest” when recommending securities… READ MORE

FINRA Streamlines Representative Qualification Exams

FINRA is restructuring its Representative level qualification exams (e.g., Series 7 and 79) to eliminate the redundancies that currently exist in the examination process. Beginning October 1, 2018, new representatives will need to take a new exam, the Security Industry Essentials (SIE) exam.  In addition, new representatives will need to take a top-off exam in… READ MORE

New FINRA Registration Categories Effective October 1st

In addition to the changes to its Principal Financial Officer and Principal Operations Officer designations, FINRA is establishing three new registration categories:  Compliance Officer, Investment Banking Principal, and Private Securities Offering Principal. These categories become effective October 1, 2018. All Chief Compliance Officers (CCOs) on Schedule A of the Form BD will have the CCO… READ MORE

Ready or Not – May 11th FINRA Customer Due Diligence Requirements Are Here

FINRA recently published an updated version of its Small Firm Template: Anti-Money Laundering (AML) Program to address amended broker-dealer requirements under FINRA Rule 3310 and the Bank Secrecy Act (“BSA”).  The amended Rule reflects the Treasury Department’s Financial Crimes Enforcement Network’s (“FinCEN”) adoption of the final rule, referred to as the Customer Due Diligence (“CDD”)… READ MORE