2015 broker/dealer compliance calendar
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2015 Broker/Dealer Compliance Calendar
Financial Registrations, Inc. 25602 Alicia Parkway #107
Laguna Hills, CA 92653 Toll-free (800) 641-1818
www.financialregistrations.com
Moving Forward
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 2 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Update: January 31, 2015 By Scott P. Tarra Managing Principal [email protected]
This 2015 Compliance Calendar is intended to inform FINRA member broker/dealers about compliance reporting requirements and filing deadlines as well as provide information on market holidays and events that may affect broker/dealer operations. This calendar is divided into two categories: compliance reporting and filing deadlines that are established on a calendar year basis and event driven requirements that are set internally by each firm based on previous year’s completion dates. While this calendar is intended to be used as a guide and reference when preparing and planning your annual compliance program, we encourage each firm to review its specific needs to determine the applicability of such requirements. As federal, state and SRO rules and regulations are subject to change, information on specific requirements as provided in this calendar should be verified to ensure compliance with current regulatory reporting guidelines.
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
Event Driven Tasks (based on previous year's completion date)
TBD
AML Continuing Education Training AML Annually AMLCO
TBD
Firm Element Continuing Education Training Education & Training Annually CCO/DSP
TBD
Annual Compliance Meeting(s) Education & Training Annually CCO/DSP
TBD
OSJ Main Office Compliance Review(s) Branch Supervision Annually CCO/DSP
TBD
OSJ Branch Office Compliance Review(s) (if applicable) Branch Supervision Annually CCO/DSP
TBD
Non-OSJ Branch Office Compliance Review(s) (if applicable) Branch Supervision Annually CCO/DSP
TBD
Independent Test of Anti-Money Laundering (AML) Program AML Annually AMLCO
TBD
Rule 3120/3130 Annual Test & Review Supervisory Controls Annually CCO/DSP
TBD
Rule 3130 Annual CEO Certification Supervisory Controls Annually CEO
Date Driven Tasks (based on Calendar Year due dates)
01/01/15 New Year’s Day Market Holiday Annually
01/04/15 2015 Final Renewal Statement Availability Renewals Annually FINOP
01/07/15
Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal
01/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
01/15/15
Quarterly Reporting of Customer Complaints (Quarter End December 31, 2014) Regulatory Reporting Quarterly CCO
01/16/15
Deadline for receipt of Final Renewal Statement payments Renewals Annually FINOP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 3 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
01/19/15 Martin Luther King, Jr. Day Market Holiday Annually
01/20/15
Short-Interest Reporting Deadline (Settlement Date of January 15, 2015) Financial Reporting Bi-Weekly FINOP
01/20/15
Automatic Transfers for 2015 Final Renewal Statement Payments Renewals Annually FINOP
01/27/15
Annual Schedule I Filing (for FYE December 31, 2014) Financial Reporting Annually FINOP
01/27/15
Quarterly FOCUS II/IIA Filing (Quarter End December 31, 2014) Financial Reporting Quarterly FINOP
01/27/15
Form Custody (Quarter End December 31, 2014) Financial Reporting Quarterly FINOP
01/27/15
Complete Monthly Financials and Net Capital Calculation (Period End December 31, 2014) Financial Reporting Monthly FINOP
01/27/15
Annual Contact Verification for FINRA and MSRB firms (FCS) Regulatory Reporting Annually CCO
01/27/15
MSRB Form A-12 Annual Affirmation (formerly MSRB G-40; MSRB Member Firms) Munis. Annually Muni Principal
01/29/15
Annual Audit Report (for FYE November 30, 2014) Financial Reporting Annually FINOP
01/30/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End December 31, 2014) Financial Reporting Monthly FINOP
01/30/15
Supplemental Statement of Income (SSOI) (Quarter End December 31, 2014) Financial Reporting Quarterly FINOP
01/31/15
MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal
01/31/15
Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader
01/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
02/03/15
Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending December 31, 2014) Financial Reporting Quarterly FINOP
02/03/15
Short-Interest Reporting Deadline (Settlement Date of January 30, 2015) Financial Reporting Bi-Weekly FINOP
02/09/15
Customer Margin Balance Form Filing (Period End January 31, 2015) Financial Reporting Monthly FINOP
02/12/15
Annual Entitlement User Accounts Certification Process (for SAA) Regulatory Reporting Annually CCO
02/15/15 Month-end Compliance Review & Recap (month-end January 31, 2015) Supervision Monthly CCO/DSP
02/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
02/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
02/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
02/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 4 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
02/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
02/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
02/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
02/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
02/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
02/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
02/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
02/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
02/16/15 President’s Day Market Holiday Annually
02/18/15
Short-Interest Reporting Deadline (Settlement Date of February 13, 2015) Financial Reporting Bi-Weekly FINOP
02/25/15
Monthly and Fifth FOCUS II/IIA Filing (Period End January 31, 2015) Financial Reporting Monthly FINOP
02/25/15
Complete Monthly Financials and Net Capital Calculation (Period End January 31, 2015) Financial Reporting Monthly FINOP
02/28/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
03/02/15
SIPC-7 General Assessment Reconciliation Filing and Payment (for firms with December 31st FYE) Financial Reporting Bi-Annually FINOP
03/02/15
Annual Audit Report (for FYE December 31, 2014) Financial Reporting Annually FINOP
03/02/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End January 31, 2015) Financial Reporting Monthly FINOP
03/03/15
Short-Interest Reporting Deadline (Settlement Date of February 27, 2015) Financial Reporting Bi-Weekly FINOP
03/09/15
Customer Margin Balance Form Filing (Period End February 27, 2015) Financial Reporting Monthly FINOP
03/15/15 Month-end Compliance Review & Recap (month-end February 28, 2015) Supervision Monthly CCO/DSP
03/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
03/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
03/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
03/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
03/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 5 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
03/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
03/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
03/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
03/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
03/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
03/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
03/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
03/17/15
Short-Interest Reporting Deadline (Settlement Date of March 13, 2015) Financial Reporting Bi-Weekly FINOP
03/24/15
Monthly and Fifth FOCUS II/IIA Filing (Period End February 28, 2015) Financial Reporting Monthly FINOP
03/24/15
Complete Monthly Financials and Net Capital Calculation (Period End February 28, 2015) Financial Reporting Monthly FINOP
03/27/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End February 28, 2015) Financial Reporting Monthly FINOP
03/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
04/01/15
Annual Audit Report (for FYE January 31, 2015) Financial Reporting Annually FINOP
04/01/15
FINRA Gross Income Assessments (GIA) through E-Bill Financial Reporting Annually FINOP
04/02/15
Short-Interest Reporting Deadline (Settlement Date of March 31, 2015) Financial Reporting Bi-Weekly FINOP
04/03/15 Good Friday Market Holiday Annually
04/07/15
Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal
04/09/15
Customer Margin Balance Form Filing (Period End March 31, 2015) Financial Reporting Monthly FINOP
04/15/15 Month-end Compliance Review & Recap (month-end March 31, 2015) Supervision Monthly CCO/DSP
04/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
04/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
04/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
04/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
04/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 6 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
04/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
04/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
04/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
04/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
04/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
04/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
04/15/15
Quarterly Reporting of Customer Complaints (Quarter Ending March 31, 2015) Regulatory Reporting Quarterly CCO
04/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
04/17/15
Short-Interest Reporting Deadline (Settlement Date of April 15, 2015) Financial Reporting Bi-Weekly FINOP
04/24/15
Quarterly FOCUS II/IIA Filing (Quarter End March 31, 2015) Financial Reporting Quarterly FINOP
04/24/15
Form Custody (Quarter End March 31, 2015) Financial Reporting Quarterly FINOP
04/24/15
Complete Monthly Financials and Net Capital Calculation (Period End March 31, 2015) Financial Reporting Monthly FINOP
04/29/15
Supplemental Statement of Income (SSOI) (Quarter End March 31, 2015) Financial Reporting Quarterly FINOP
04/29/15
Annual Audit Report (for FYE February 28, 2015) Financial Reporting Annually FINOP
04/29/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End March 31, 2015) Financial Reporting Monthly FINOP
04/30/15
Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader
04/30/15
MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal
04/30/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
05/01/15
Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending March 31, 2015) Financial Reporting Quarterly FINOP
05/04/15
Short-Interest Reporting Deadline (Settlement Date of April 30, 2015) Financial Reporting Bi-Weekly FINOP
05/08/15
Customer Margin Balance Form Filing (Period End April 30, 2015) Financial Reporting Monthly FINOP
05/15/15 Month-end Compliance Review & Recap (month-end April 30, 2015) Supervision Monthly CCO/DSP
05/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
05/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 7 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
05/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
05/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
05/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
05/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
05/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
05/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
05/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
05/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
05/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
05/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
05/19/15
Short-Interest Reporting Deadline (Settlement Date of May 15, 2015) Financial Reporting Bi-Weekly FINOP
05/22/15 Day before Memorial Day (3 p.m. early close) Market Holiday Annually
05/25/15 Memorial Day Market Holiday Annually
05/26/15
Monthly and Fifth FOCUS II/IIA Filings (Period End April 30, 2015) Financial Reporting Monthly FINOP
05/26/15
Complete Monthly Financials and Net Capital Calculation (Period End April 30, 2015) Financial Reporting Monthly FINOP
05/29/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End April 30, 2015) Financial Reporting Monthly FINOP
05/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
06/01/15
Annual Audit Report (for FYE March 31, 2015) Financial Reporting Annually FINOP
06/02/15
Short-Interest Reporting Deadline (Settlement Date of May 29, 2015) Financial Reporting Bi-Weekly FINOP
06/08/15
Customer Margin Balance Form Filing (Period End May 29, 2015) Financial Reporting Monthly FINOP
06/15/15 Month-end Compliance Review & Recap (month-end May 31, 2015) Supervision Monthly CCO/DSP
06/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
06/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
06/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
06/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 8 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
06/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
06/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
06/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
06/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
06/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
06/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
06/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
06/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
06/17/15
Short-Interest Reporting Deadline (Settlement Date of June 15, 2015) Financial Reporting Bi-Weekly FINOP
06/23/15
Monthly and Fifth FOCUS II/IIA Filing (Period End May 31, 2015) Financial Reporting Monthly FINOP
06/23/15
Complete Monthly Financials and Net Capital Calculation (Period End May 31, 2015) Financial Reporting Monthly FINOP
06/26/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End May 31, 2015) Financial Reporting Monthly FINOP
06/29/15
Annual Audit Report (for FYE April 30, 2015) Financial Reporting Annually FINOP
06/30/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
07/01/15
Effective Date of FINRA Rule 3110(e) (Responsibility of Member to Investigate Applicants for Registration) Personnel As Needed CCO
07/01/15
FINRA Rule 4311(h)(2) Notification (Clearing Report Availability) Trading Annually CCO
07/02/15
Short-Interest Reporting Deadline (Settlement Date of June 30, 2015) Financial Reporting Bi-Weekly FINOP
07/02/15 Day before Independence Day (1 p.m. early close) Market Holiday Annually
07/03/15 Independence Day (observed) Market Holiday Annually
07/07/15
Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal
07/09/15
Customer Margin Balance Form Filing (Period End June 30, 2015) Financial Reporting Monthly FINOP
07/15/15
Quarterly Reporting of Customer Complaints (Quarter Ending June 30, 2015) Regulatory Reporting Quarterly CCO
07/15/15 Month-end Compliance Review & Recap (month-end June 30, 2015) Supervision Monthly CCO/DSP
07/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 9 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
07/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
07/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
07/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
07/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
07/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
07/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
07/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
07/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
07/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
07/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
07/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
07/17/15
Short-Interest Reporting Deadline (Settlement Date of July 15, 2015) Financial Reporting Bi-Weekly FINOP
07/24/15
Form Custody (Quarter End June 30, 2015) Financial Reporting Quarterly FINOP
07/24/15
Quarterly FOCUS II/IIA Filing (Quarter End June 30, 2015) Financial Reporting Quarterly FINOP
07/24/15
Complete Monthly Financials and Net Capital Calculation (Period End June 30, 2015) Financial Reporting Monthly FINOP
07/29/15
Supplemental Statement of Income (SSOI) (Quarter End June 30, 2015) Financial Reporting Quarterly FINOP
07/29/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End June 30, 2015) Financial Reporting Monthly FINOP
07/30/15
Annual Audit Report (for FYE May 31, 2015) Financial Reporting Annually FINOP
07/30/15
SIPC-6 General Assessment Filing and Payment (for firms with December 31st FYE) Financial Reporting Bi-Annually FINOP
07/31/15
Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending June 30, 2015) Financial Reporting Quarterly FINOP
07/31/15
Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader
07/31/15
MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal
07/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
08/04/15
Short-Interest Reporting Deadline (Settlement Date of July 31, 2015) Financial Reporting Bi-Weekly FINOP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 10 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
08/10/15
Customer Margin Balance Form Filing (Period End July 31, 2015) Financial Reporting Monthly FINOP
08/15/15 Month-end Compliance Review & Recap (month-end July 31, 2015) Supervision Monthly CCO/DSP
08/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
08/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
08/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
08/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
08/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
08/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
08/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
08/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
08/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
08/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
08/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
08/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
08/18/15
Short-Interest Reporting Deadline (Settlement Date of August 14, 2015) Financial Reporting Bi-Weekly FINOP
08/25/15
Monthly and Fifth FOCUS II/IIA Filing (Period End July 31, 2015) Financial Reporting Monthly FINOP
08/25/15
Complete Monthly Financials and Net Capital Calculation (Period End July 31, 2015) Financial Reporting Monthly FINOP
08/28/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End July 31, 2015) Financial Reporting Monthly FINOP
08/31/15
Annual Audit Report (for FYE June 30, 2015) Financial Reporting Annually FINOP
08/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
09/02/15
Short-Interest Reporting Deadline (Settlement Date of August 29, 2015) Financial Reporting Bi-Weekly FINOP
09/04/15 Friday before Labor Day (3 p.m. early close) Market Holiday Annually
09/07/15 Labor Day Market Holiday Annually
09/09/15
Customer Margin Balance Form Filing (Period End August 31, 2015) Financial Reporting Monthly FINOP
09/15/15 Month-end Compliance Review & Recap (month-end August 31, 2015) Supervision Monthly CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 11 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
09/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
09/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
09/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
09/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
09/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
09/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
09/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
09/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
09/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
09/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
09/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
09/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
09/17/15
Short-Interest Reporting Deadline (Settlement Date of September 15, 2015) Financial Reporting Bi-Weekly FINOP
09/24/15
Monthly and Fifth FOCUS II/IIA Filing (Period End August 31, 2015) Financial Reporting Monthly FINOP
09/24/15
Complete Monthly Financials and Net Capital Calculation (Period End August 31, 2015) Financial Reporting Monthly FINOP
09/29/15
Annual Audit Report (for FYE July 31, 2015) Financial Reporting Annually FINOP
09/29/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End August 31, 2015) Financial Reporting Monthly FINOP
09/30/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
10/01/15
Review of all registered persons and branch offices for proper reporting through Web CRD® in preparation for 2016 Renewals Renewals Annually FINOP
10/02/15
Short-Interest Reporting Deadline (Settlement Date of September 30, 2015) Financial Reporting Bi-Weekly FINOP
10/07/15
Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal
10/08/15
Customer Margin Balance Form Filing (Period End September 30, 2015) Financial Reporting Monthly FINOP
10/12/15 Columbus Day Federal Holiday Annually
10/15/15
Quarterly Reporting of Customer Complaints (Quarter Ending September 30, 2015) Regulatory Reporting Quarterly CCO
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 12 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
10/15/15 Month-end Compliance Review & Recap (month-end September 30, 2015) Supervision Monthly CCO/DSP
10/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
10/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
10/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
10/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
10/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
10/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
10/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
10/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
10/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
10/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
10/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
10/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
10/19/15
Short-Interest Reporting Deadline (Settlement Date of October 15, 2015) Financial Reporting Bi-Weekly FINOP
10/23/15
Quarterly FOCUS II/IIA Filings (Quarter End September 30, 2015) Financial Reporting Quarterly FINOP
10/23/15
Form Custody (Quarter End September 30, 2015) Financial Reporting Quarterly FINOP
10/26/15
Firms may begin to submit post-dated Forms U5 and BR Closing/Withdrawal (must be dated 12/31/14) as part of 2016 Renewals Renewals Annually FINOP
10/28/15
Complete Monthly Financials and Net Capital Calculation (Period End September 30, 2015) Financial Reporting Monthly FINOP
10/28/15
Supplemental Statement of Income (SSOI) (Quarter End September 30, 2015) Financial Reporting Quarterly FINOP
10/28/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End September 30, 2015) Financial Reporting Monthly FINOP
10/30/15
Annual Audit Report (for FYE August 31, 2015) Financial Reporting Annually FINOP
10/30/15
Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending September 30, 2015) Financial Reporting Quarterly FINOP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 13 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
10/31/15
MSRB Rule A-14 (Annual Fee) Munis. Annually Muni Principal
10/31/15
Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader
10/31/15
MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal
10/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
11/01/15
Firms may begin to submit post-dated Forms BDW and ADV-W (must be dated 12/31/14) as part of 2016 Renewals Renewals Annually FINOP
11/03/15
Short-Interest Reporting Deadline (Settlement Date of October 30, 2015) Financial Reporting Bi-Weekly FINOP
11/09/15
Customer Margin Balance Form Filing (Period End October 30, 2015) Financial Reporting Monthly FINOP
11/09/15
Preliminary 2016 Renewal Statements and reports are available for viewing and printing Renewals Annually FINOP
11/11/15 Veterans Day Federal Holiday Annually
11/15/15 Month-end Compliance Review & Recap (month-end October 31, 2015) Supervision Monthly CCO/DSP
11/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
11/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
11/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
11/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
11/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
11/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
11/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
11/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
11/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
11/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
11/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
11/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
11/17/15
Short-Interest Reporting Deadline (Settlement Date of November 13, 2015) Financial Reporting Bi-Weekly FINOP
11/25/15
Monthly and Fifth FOCUS II/IIA Filing (Period End October 31, 2015) Financial Reporting Monthly FINOP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 14 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
11/25/15
Complete Monthly Financials and Net Capital Calculation (Period End October 31, 2015) Financial Reporting Monthly FINOP
11/25/15 Day before Thanksgiving Day(3 p.m. early close) Market Holiday Annually
11/26/15 Thanksgiving Day Market Holiday Annually
11/27/15 Day after Thanksgiving Day (1 p.m. early close) Market Holiday Annually
11/30/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
11/30/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End October 31, 2015) Financial Reporting Monthly FINOP
11/30/15
Annual Audit Report (for FYE September 30, 2015) Financial Reporting Annually FINOP
12/02/15
Short-Interest Reporting Deadline (Settlement Date of November 30, 2015) Financial Reporting Bi-Weekly FINOP
12/08/15
Customer Margin Balance Form Filing (Period End November 30, 2015) Financial Reporting Monthly FINOP
12/11/15
Deadline for receipt of 2016 Preliminary Renewal Statement payments Renewals Annually FINOP
12/14/15
Automatic Transfers for 2016 Preliminary Renewal Statements Renewals Annually FINOP
12/15/15 Month-end Compliance Review & Recap (month-end November 30, 2015) Supervision Monthly CCO/DSP
12/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
12/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
12/15/15 Sample Review of Transactions Trading Monthly CCO/DSP
12/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP
12/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP
12/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
12/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
12/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
12/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
12/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
12/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
12/15/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
12/17/15
Short-Interest Reporting Deadline (Settlement Date of December 15, 2015) Financial Reporting Bi-Weekly FINOP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 15 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
12/23/15
Monthly and Fifth FOCUS II/IIA Filing (Period End November 30, 2015) Financial Reporting Monthly FINOP
12/23/15
Complete Monthly Financials and Net Capital Calculation (Period End November 30, 2015) Financial Reporting Monthly FINOP
12/24/15 Day before Christmas (1 p.m. early close) Market Holiday Annually
12/25/15 Christmas Day Market Holiday Annually
12/26/15
Last Day to submit 2016 Preliminary Renewal Filing and Payment prior to year-end Renewals Annually FINOP
12/29/15
Web CRD/IARD are unavailable due to 2016 Final Renewal Statement and renewals processing Renewals Annually FINOP
12/29/15
Supplemental Inventory Schedule (SIS) Filing (Quarter End November 30, 2015) Financial Reporting Monthly FINOP
12/30/15
Annual Audit Report (for FYE October 31, 2015) Financial Reporting Annually FINOP
12/30/15
Web CRD/IARD are available for QUERY-only and the creation of "Pending" 2016 Renewal filings Renewals Annually FINOP
12/31/15
FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO
12/31/15
Mailing of Annual Disclosure Documents to Clients (Privacy Policy; BCP; AML, etc.) Communications Annually CCO
12/31/15 Year-end Compliance Review & Recap (2015) Supervision Annually CCO/DSP
12/31/15 Year-End Compliance Review Checklist Supervision Annually CCO/DSP
12/31/15 Year-End Review/Update of Written Supervisory Procedures- Review and Approval by CCO Internal Controls Annually CCO/DSP
12/31/15 Year-End Review/Update of Continuing Education Program (CEP)- Review and Approval by CCO Education & Training Annually CCO/DSP
12/31/15 Year-End Review/Update of Business Continuity Plan (BCP)- Review and Approval by CCO Internal Controls Annually CCO/DSP
12/31/15 Year-End Review/Update of Supervisory Control System (WSCS)- Review and Approval by CCO Internal Controls Annually CCO/DSP
12/31/15 Year-End Review/Update of AML Program- Review and Approval by AMLCO AML Annually AMLCO
12/31/15 Year-End Review/Update of Cybersecurity Procedures- Review and Approval by CCO Cybersecurity Annually CCO/CIO
12/31/15 Year-End Review/Update of Privacy Policy- Review and Approval by CCO Internal Controls Annually CCO/DSP
12/31/15 Year-End Review of Vendors & Service Providers (Contracts & Service Level) Due Diligence Annually CCO/DSP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 16 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
12/31/15 Year-End Review of Associated Persons List (Including Recently Hired/Terminated Rep Lists) Personnel Annually CCO/DSP
12/31/15 Annual Review of FINRA Membership Agreement and Form BD Regulatory Reporting Annually CCO/DSP
12/31/15 Year-End Review and Update of Form BR Filings (Branch Offices) Branch Supervision Annually CCO/DSP
12/31/15 Year-End Review and Update of Expense Sharing Agreement (if applicable) Financial Reporting Annually FINOP
01/05/16
Short-Interest Reporting Deadline (Settlement Date of December 31, 2015) Financial Reporting Bi-Weekly FINOP
01/11/16
Customer Margin Balance Form Filing (Period End December 31, 2015) Financial Reporting Monthly FINOP
01/15/16
Quarterly Reporting of Customer Complaints (Quarter Ending December 31, 2015) Regulatory Reporting Quarterly CCO
01/15/16 Month-end Compliance Review & Recap (month-end December31, 2015) Supervision Monthly CCO/DSP
01/15/16 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP
01/15/16 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP
01/15/16 Sample Review of Transactions Trading Monthly CCO/DSP
01/15/16 Sample Review of New Rep files Personnel Monthly CCO/DSP
01/15/16 Review of Customer Complaints Internal Controls Monthly CCO/DSP
01/15/16 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP
01/15/16 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP
01/15/16 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP
01/15/16 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP
01/15/16 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP
01/15/16 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP
01/27/16
Annual Schedule I Filing (for FYE December 31, 2015) Financial Reporting Annually FINOP
01/27/16
Quarterly FOCUS II/IIA Filing (Quarter End December 31, 2015) Financial Reporting Quarterly FINOP
01/27/16
Form Custody (Quarter End December 31, 2015) Financial Reporting Quarterly FINOP
01/27/16
Complete Monthly Financials and Net Capital Calculation (Period End December 31, 2015) Financial Reporting Monthly FINOP
01/29/16
Annual Audit Report (for FYE November 30, 2015) Financial Reporting Annually FINOP
2015 Broker/Dealer Compliance Calendar
Prepared by Financial Registrations, Inc. Page 17 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015
Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments
01/31/16
MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal
02/01/16
Supplemental Statement of Income (SSOI) (Quarter End December 31, 2015) Financial Reporting Quarterly FINOP
02/01/16
SIPC-7 General Assessment Reconciliation Filing and Payment (for firms with December FYE) Financial Reporting Bi-Annually FINOP
02/01/16
Supplemental Inventory Schedule (SIS) Filing (Quarter End December 31, 2015) Financial Reporting Monthly FINOP
02/03/16
Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending December 31, 2015) Financial Reporting Quarterly FINOP
02/29/16
Annual Audit Report (for FYE December 31, 2015) Financial Reporting Annually FINOP
Financial Registrations, Inc. is a compliance management consulting firm providing registration and compliance advisory services to FINRA member broker/dealers and SEC and State registered investment advisers. For more information on this topic or other compliance related matters, please contact: Brian K. Miller Vice President, Business Development [email protected]
Financial Registrations, Inc. 25602 Alicia Parkway #107 Laguna Hills, CA 92653 www.financialregistrations.com
Toll-free (800) 641-1818 Direct (949) 770-6154 Fax (949) 770-6198