BD & RIA Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

With all of the changes in the regulatory industry and the consolidation of the NYSE and NASD rule books, maybe it’s time to let Thornton & Associates’ team of former NASD/FINRA examiners either review and update your supervisory procedures or create a new customized version.

For more information about our Written Supervisory Procedures and other compliance services, please contact us at (877) 542-6759.

Anti-Money Laundering Services

Anti-Money Laundering compliance continues to be a significant focal point in FINRA, SEC and state regulatory audits and examinations. Thornton & Associates, LLC’s highly trained staff of former NASD/FINRA examiners are specialists in Anti-Money Laundering compliance. Our firm’s Anti-Money Laundering compliance solutions include:

• Independent Money Laundering Audits
• Money Laundering Audit Templates
• Anti-Money Laundering Compliance Procedures
• Anti-Money Laundering Training

Let our expert compliance team assist you in ensuring that your firm is compliant with all of its money laundering and other compliance obligations.

For more information about our Anti-Money Laundering services and other compliance solutions, please contact us at (877) 542-6759.

Registered Investment Advisory Compliance

SEC and State RIA Registration

Entitlement Forms
Prepare the FINRA Entitlement applications for the IARD/Web CRD accounts, which are required to file an application to register as an investment adviser and investment adviser representative.

Form ADV
Prepare and submit the Form ADV Part IA, Part IB, Part II, Schedule A, Schedule B, Schedule C, Schedule D and Schedule F that is customized to your firm’s unique business model.

Form U4
Prepare and submit the Form U4 (via Web CRD system) to register each IAR applicant of the firm. Verify Form U4 disclosures are consistent with Form ADV disclosures. Advise your firm as to the states that IAR will need to register at the time the firm is initially registered.

Written Supervisory Procedures
Prepare and provide your firm with a comprehensive and customized written supervisory procedure manual addressing all areas of your firm’s business. Unlike most consulting firms, you will be provided with a copy of your WSP in an editable Word version so that your firm may make any necessary changes as your firm grows.

Code of Ethics
All of our RIA clients will receive a comprehensive Code of Ethics in a Word format.

Notice Filings
Advise your firm as to those states which would require notice filing (at the time that firm submits its initial federal filing). Prepare the applications for state notice filings via the IARD system.

Written Supervisory Procedures Manual & Monthly Compliance Checklists

Every RIA is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC and state regulatory agencies and are updated to reflect changes in rules and regulations.

SEC Rule 206(4)-7 Testing

SEC Rule 206(4)-7 requires annual testing and onsite evaluation of the adequacy of the registered investment adviser policies and procedures and the effectiveness of their implementation.

Our Rule 206 testing includes a comprehensive review of the following areas:

Advisory contracts
Advisory fee arrangements
Advertising and marketing materials
Anti-money laundering procedures
Best execution
Books and records and filing systems
Code of ethics
Compliance and procedures manual
Conflicts of interest
Custody
Disaster recovery and business continuity
Fee billing
Form ADV
Gifts and entertainment, OBAs
Insider trading policy
Investment guidelines
Pay to Play
Performance materials
Previous 206(4)-7 testing results and recommendations
Risk management
SEC or State deficiency letters and responses
Soft dollars
Supervision
Trade allocation
Trading practices
Valuation

General Consulting

Our professionals have in-depth expertise regarding investment advisory regulatory requirements and broad experience in the investment adviser industry.

When you use our consulting services you will be assured that you have a compliance partner dedicated to meeting your compliance needs and keeping you in legal compliance with investment advisory regulatory requirements.

We provide compliance consulting services in the following areas:

General rule interpretation, guidance and best practices
Development and implementation of supervisory procedures
Preparation for regulatory review and inspections and inquiries
Assistance with monthly, quarterly and annual filings
Assistance with compliance matters that may arise during the course of the business day
Updates on new and amended rules
Research and answers to specific investment adviser compliance and registration questions

Financial Operations Services

Having a seasoned Financial and Operations Principal is essential to running a compliant broker dealer. Our staff is comprised of Series 27/28 licensed professionals with decades of financial and regulatory experience. Our consultants can register as your FinOp or file your FOCUS and SSOI filings on your firm’s behalf. We are proud of our staff’s accuracy and wealth of accounting and regulatory knowledge.

Our monthly FinOp Packages include the preparation, review, and approval of the following:

• FOCUS II or IIA
• Supplementary Statement of Income (“SSOI”)
• Broker Dealer Form Custody Filings
• Monthly Net Capital Computation
• Supplemental Inventory Schedule (“SIS”)
• SIPC Assessment
• FINRA Annual Assessment
• Balance Sheet
• Trial Balance
• Income statement
• General Ledger
• Third Party Verification of Allowable Assets with Reconciliations
• Bank Statement and Reconciliation Review
• Onsite Review of Financial Records with Written Report
• Review and Approval of Audited Financial Statements

For more information about our FinOp services, please contact us at (877) 542-6759.

Broker Dealer Compliance

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations. Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal. Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

3110(e) Background Checks

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

Online Continuing Education

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

State Registrations

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

Annual Compliance Meetings

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

3110 Internal Audits

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

3120 / 3130 Supervisory Testing

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

Written Supervisory Procedures

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

Comprehensive Compliance Services

AML Audits

For more information about our AML audit services, please contact us at (877) 542-6759.

Comprehensive Compliance Services

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

Conduct a comprehensive FINRA Rule 3010 Internal Audit
Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
Conduct the annual Regulation SP Privacy Policy Audit
Complete the annual Business Continuity Plan review.
Update the firm’s OSJ and branch office audit program.
Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
Moderate the annual CEO/CCO 3120/3130 meeting
Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

Conduct an Independent Anti Money Laundering Audit
Conduct the firm’s Anti Money Laundering Training
Revise and update the firm’s Anti Money Laundering Procedures
Review and update the firm’s Customer Identification Program
Prepare and review the annual CEO Anti Money Laundering Program Certification
Assist in filing SAR’s if needed

Continuing Education

Prepare the annual Needs Analysis
Prepare the annual Training Plan
Coordinate and monitor the firm’s online continuing education completion progress
Update the firm’s Regulatory Element Plan
Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

Review and submit advertising to the FINRA Advertising Department
Review sales literature as needed
Complete a monthly email review

CRD Maintenance

Prepare and submit all Form U4 filings
Amend the Form BD as necessary
Conduct a monthly review to ensure that all CRD deficiencies are corrected
File all state registration applications as needed

Miscellaneous

Moderate the firm’s Annual Compliance Meeting
Conduct the annual FINRA Contact Questionnaire update
Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
Conduct a monthly best execution review (if applicable)
Review the firm Fidelity Bond renewal
Update the firm MSRB G-40 contact information report
Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
Q&A as needed

3110(e) Background Checks

Download white paper here.
Read related blog here.
Request information here.

3120 / 3130 Supervisory Testing

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Both of our audit templates and on-site audit services include a review of the following:

Financial Statements and Net Capital
Written Supervisory Procedures
Books and Records review
Email and Correspondence
Website compliance
Transaction reporting
Continuing Education
Money Laundering
Suitability

Online Continuing Education

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

Written Supervisory Procedures

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

State Registrations

For assistance in state registrations, please contact us at (877) 542-6759.

FINRA New Member Applications

The FINRA New Member Process can be a complex and arduous process requiring professional assistance. Thornton & Associates, LLC are experts in broker dealer applications. Our firm worked directly with FINRA in developing the current New Member Application process that was launched in the beginning of 2008. Our consultants have assisted dozens of new FINRA applicants through the application process. Our staff will work with your firm and take your firm through the entire approval process in a professional and efficient manner. We are convinced that Thornton & Associates is the most efficient and cost effective solution to your New Membership Application needs.

As part of our FINRA New Membership Application services, Thornton & Associates will either provide on behalf of the applicant or assist the applicant in preparing and submitting the following information and documentation:

Name reservation for the applicant with FINRA
CRD and Form NMA entitlement filings
Completion and filing of Form NMA
Conduct a mock FINRA Pre-Membership Interview
Accompany the firm to the FINRA Pre-Membership Interview
Form BD with applicable schedules and all subsequent amendments
Form U-4 for each associated person required to register as a principal and/or representative under the rules of the association and assistance in completing it
Form BR for office registration
FINRA-approved fingerprint card for each associated person subject to SEC Rule 17f-2
New Member Assessment Report
Business Plan
AML compliance program and procedures
An analysis of temporary or permanent adverse decisions regarding an Applicant’s or associated person’s securities registration or license
Documentation of any criminal or regulatory action and any customer complaint, civil action, or arbitration against the Applicant or an associated person
Documentation of any “termination for cause” or “permitted to resign” involving alleged violation(s) of rules, regulations, or industry standards of conduct
Description of any remedial training or continuing education or heightened supervision imposed by a state, federal, or self-regulatory organization (SRO) authority and acknowledgments of same
Copies of all draft or final agreements relating to the securities business, including those with banks, clearing entities, or service bureaus
Evidence that the Applicant has or will have adequate plans to obtain facilities that are sufficient to initiate the securities operations
Email archiving vendor and applicable electronic storage filings
Description and documentation of the nature and source of Applicant’s capital
Description of financial controls
Description of the communications and operational systems.
Description of all supervisors and principals
Description of Applicant’s record keeping system
Complete Continuing Education Plan (Needs Analysis and Training Plan)
Written Supervisory Procedures Manual and Checklist
Written Supervisory Compliance System
Outside Business Activities Questionnaire and 3270 analysis
Private Securities Transaction Questionnaire
Trial balance and balance sheet and net capital computations with supporting schedules
Monthly projections of income and expenses for the first 12 months of operation
A description of the general products to be offered and sold
A profile of the intended customer base with specific reference to the portions that would be retail and institutional
A description of the marketing techniques to attract customers such as brochures, seminars, telemarketing efforts, mailings, technological media (e.g., the Internet)
Social media marketing plan
A description of the firm’s intentions to enter into contractual commitments such as underwritings or other securities-related activities
Type Of Organization And Organizational Chart
Personnel And Recruitment
A description of the business facilities, including location, the number of persons that such facilities will support
Disclosure of leases entered into, or that are expected to be entered into, including the terms and conditions together with the parties to the agreement
Documentation of sources of capital used to fund the firm including, but not limited to, bank statements, canceled checks, and corporate minutes
Business Continuity Plan
Filing the application for the requisite Fidelity Bond
Filing and amending all requisite documents via the WebCRD system
Process all state registrations (per the letter of engagement)

We will compile and prepare all the required documentation for the New Membership Application in a professional portfolio and submit it to FINRA. Additionally, we will quickly respond to any request from FINRA for additional information or clarification of material submitted.

We are convinced that Thornton & Associates is the most efficient and cost effective solution to your New Membership Application needs.

Resources

FINRA Exams & Licenses
FINRA Fee Schedule
FINRA Regulatory Notice 12-32
Broker Dealer Name Reservation Form – FINRA
Super Account Administrator & Entitlement Agreement
FINRA Form NMA
Form NMA Frequently Asked Questions
Form BD

FINRA Continuance in Membership Applications

The FINRA Membership Rules require that existing broker dealers file a continuance in Membership Application under certain circumstances:

These circumstances may include:

The purchase or sale of a broker/dealer
Changes in ownership, management, corporate restructuring, control or transfers of the assets of the firm
The additions of new authorized product or business lines
The addition of registered/associated personnel or office locations
Modification or the elimination of restrictions contained in the broker dealer’s FINRA Membership Agreement
Changes in business operations or
Other “material” changes in the firm’s business that fall outside of the “Safe Harbor” provisions of the Membership Rules

The FINRA Continuance in Membership Application Process (“CMA”) can be a complex and time consuming process requiring professional assistance. Our consultants have assisted over one hundred FINRA broker/dealers through the CMA process. Our staff will work with your firm and take your firm through the entire CMA approval process in a professional manner.   We are convinced that Thornton & Associates, LLC is the most efficient and cost effective solution to your CMA needs. Our services include:

Materiality Consult Applications (if applicable)
FINRA Membership Rule “Safe Harbor” analysis
CMA planning and business transition planning
Application coordination with FINRA Membership Application Department
Application review and filing
FINRA request for supplemental information response
FINRA interview preparation (if needed)

Resources

FINRA Form CMA
FINRA Regulatory Notice 12-33 (Membership Application Changes)
FINRA Regulatory Notice 12-32 (FINRA Application Fees)
Continuance in Membership Applications (www.FINRA.org)
Continuing Membership Guide (www.FINRA.org)
FINRA Membership Application Rules (NASD Rule 1017)

Should I buy a “Shell BD” or File a New Member Application?

Thornton & Associates, LLC is constantly asked which is better, buying an existing Broker Dealer (“BD”)/”Shell” BD or starting from scratch. Although there is no easy answer to this question, there are several areas to consider when making this decision. We have broken it down to the following areas:

Time – The amount of time it takes to get a Continuance in Membership Application (“CMA”) (Change in Ownership) application approved as opposed to a New Member Application (“NMA”).
Cost – Application, acquisition, transaction and consultant costs.
Conducting Business During Application – Can we conduct business during the application process?

Definitions
In order to understand the differences between acquiring a Broker Dealer and starting from scratch, it is important to understand the terms and acronyms associated with these processes.

New Member Application or (“NMA”)

This is an application for either a new entity or an established entity that has not previously engaged in a securities business to become a FINRA member Broker Dealer or (“BD”).

Continuance in Membership Application or (“CMA”)

A CMA is an application to FINRA for:

A change in ownership of more that 25% of an existing FINRA member Broker Dealer
A change in the number of offices or associated personnel it is permitted to have
A change in any restrictions that FINRA has included in the firm’s Membership Agreement
An application to add new lines of business to an existing BD
Any material change in the BD’s operations.

FINRA Membership Agreement

Each FINRA member Broker Dealer has a formal agreement with FINRA that establishes:

The lines of business that the BD is permitted to engage in
The number of associated personnel it is permitted to employ
The number of office locations it is permitted to have
Any other restrictions on the firm’s business operations that FINRA deems appropriate.

Any changes in the agreement may require a Continuance in Membership Application or a CMA.

Time
The maximum amount of time an NMA or a CMA is permitted to take is 180 days from when an application is submitted. Once FINRA receives any application they have 30 days to review it. FINRA will then send the applicant a letter requesting additional documentation or information. Once the applicant receives FINRA’s response, they in turn have 30 days to respond. This back and forth will continue until the application (NMA or CMA) is approved.

There are several variables to consider when an applicant is deciding whether or not to buy an existing BD or to start from scratch.
When buying a BD a purchaser must:

Identify a potential takeover candidate
Negotiate the terms and price of the purchase
Conduct due diligence of the broker dealer’s BD and its prior business.

It is important to note that anyone who is purchasing a BD must be VERY wary of anyone who claims to have a “shell” or a “clean” BD. The truth is that FINRA does not permit its members to exist in a “shell” state. FINRA requires all BD’s to report their financial and P&L information at least quarterly. If FINRA discovers that a FINRA BD is not reporting any income or expenses over an extended period of time, they will open an investigation and will ultimately force the BD to shut down due to a lack of business.

Finally, it is up to the buyer to determine what is or isn’t a “clean” BD and not the seller. Purchasers must conduct thorough and complete due diligence on any BD they purchase. Many purchasers of BDs are sold on the concept that they are buying a “clean” BD or that the seller will indemnify the new owners if there are any customer complaints or litigation that arise subsequent to the purchase. Purchasers must remember that the indemnification is only as good as your ability to collect.

Sign a Purchase Agreement
Prepare and submit the application

When establishing a new BD, the applicant must:

Establish a new entity or use an existing entity as the BD
Fund the entity (if a new entity)
Create all corporate documents
Prepare and submit an application.

In most instances, it is easier and takes less time to start a new BD than to purchase an existing entity and conduct due diligence.

Most people believe that once the application is submitted, that a CMA takes far less time that an NMA to get regulatory approval. The truthfulness of that must be determined on a case by case basis.

“Shell” BD Additional Costs

Attorney fees for drafting purchase agreement
Due diligence costs
Purchase costs (typically $25,000 and up)
Additional capital as needed (The firm should have 6-12 months of fixed operating costs in reserve)
Consulting fees for application (TAA fees are essentially the same for a CMA or an NMA)

Start Up Firm Additional Costs

Corporate filing fees
Attorney fees for starting a new entity
Fidelity Bond
BD Funding (12 months of fixed operating costs)
Consulting fees for application (TAA fees are essentially the same for a CMA or an NMA)
State registration fees

Conducting Business during the Application

The concept of doing business during the application process is commonly misunderstood. Many people believe that if you are purchasing a BD that you can conduct business. That however is not necessarily the case. There are very specific conditions that must exist for that to happen. The conditions are as follows:

The broker dealer must currently be approved by FINRA to conduct the business that the purchaser wants to engage in. If the purchaser wishes to engage in business that is not currently permitted under the BD’s current Membership Agreement, then the purchaser must wait until the application is approved before engaging in that business.
Even if the BD is approved for the product lines that the purchaser wishes to engage in, the purchaser still may not be able to engage in that business during the application process. If the business is materially different in the method of solicitation, execution, reporting or a material increase in the existing volume, then FINRA may require that the purchaser wait until the application is approved prior to engaging in the business. The purchaser must also demonstrate that they have the experience, appropriate number of supervisors, policies and procedures, books and records and the operational bandwidth to engage in the proposed business. Under this standard, a “Shell” or an inactive BD would not be able to conduct business until the application is approved because the new business would be materially different from the BD’s existing business.
The existing BD must have the ability to register all of the reps that the purchaser would like to bring on board. FINRA sets limits on the number of “Associated” persons that each BD may bring on board under the firm’s Membership Agreement. Although there are provisions in the FINRA rules that permit the firm to add “Associated” person above the limits in the Membership Agreement, there are very specific conditions and standards that the firm must met to be eligible for this exemption.

Registering with another BD during the application process

Many firms have found it useful to temporarily register with another BD while going through the application process. This is perfectly acceptable by FINRA as long as all parties understand and that the registered personnel are either starting a BD or acquiring a BD. There are however some issues with this as well.

All engagement agreements must be signed by the firm that reps are registered with. Should the reps want to move to their new firm, all engagements must be assigned to the new BD. This sometimes creates conflicts with the prior BD and with the customer.
The old BD must maintain all of the books and records of the transaction during the time that the reps were registered with the firm.
The prior BD also will retain some carryover liability for the transaction even after the transaction is assigned to the new BD.

The decision as to whether or not to purchase a BD and go through the CMA process or to start a BD from scratch is a complicated one. Should you have any additional questions, please contact us at (877) 542-6759.

Whether you are starting a new broker dealer or purchasing an existing entity, FINRA will assess an application fee. The fees are outlined below.

FINRA New Membership Application Fees

FINRA Continuance in Membership Application Fees

* These fees are exclusively the one time application fee charged by FINRA filing a New Member Application. These fees do not include any other fees and charges associated with a New Member Application for registering individual brokers, state registration fees, FINRA exam fees, or any other fees and assessments associated with the application. These fees also do not include any consulting or advisory fees charges by Thornton & Associates.