SCA has assisted firms through the FINRA membership process since 1998, and all of our clients have successfully gained membership. The regulatory and industry experience our team offers can reduce the risk of delayed or abandoned registrations, additional work delays and costly legal issues.
We provide a fully customized program for new broker dealer clients. The cornerstone of a firm’s compliance program is an effective set of supervisory and compliance procedures and supervisory control procedures that are reasonably designed to achieve compliance with all applicable securities laws, regulations and rules of the FINRA and MSRB. We take the time to understand your business model and prepare policies and procedures that address your unique compliance needs. You will have the benefit of a solid foundation from the beginning.
Our training program during the application further distinguishes us from the competition. By the time your firm receives regulatory approval, your principals and staff will understand how to implement the required systems and procedures so that you can “hit the ground running.” You will also be better prepared for your new member FINRA audit.
We will prepare and file all required documents including the Form NMA for broker dealer registration with the SEC, FINRA, MSRB and state and foreign jurisdictions.
Broker dealers wishing to materially change their ownership structure, purchase or sell firm assets or materially expand their business are required to file an application known as the continuing membership application (CMA) and obtain FINRA approval. Because SCA has filed a number of CMAs we understand obstacles that may arise during the process. We work with clients to satisfy FINRA requirements and concerns at the outset of the process, to the extent possible, in order to avoid delays and rejected applications. SCA consultants will lead the CMA project or act in an advisory capacity depending upon the needs of the client.
If there is a question as to whether a business expansion is “material” under FINRA guidance, we may prepare a materiality consultation letter setting forth the business expansion and the reasons we believe a CMA should not be required and submit to FINRA.