2015 SILA National Education Conference
FINRA Testing & Continuing Education, Registration &
Disclosure Roadmap and Member Relations Updates October 5, 2015 • Nashvillle, TN
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Regulatory Element Continuing Education Program
• Started in 1995 – S101 only
• Introduction of the S106 and S201 Programs
• Redesign of the Regulatory Element Program 2007 – 2010
• Launch of S901 for Operations Professionals
• Introduction of Web Delivery – 2015
■ Qualification Exams
• Long history – starting in 1956 with the Series 1
• Exams have been added as the industry has grown and new products have
been created.
2
Evolution of CE and Qualification Exams
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Qualification Examination History
Examination Implementation Timeline
1955 1960 1970 1980 1995 2000 2005 2010 2012
Examination Implementation Timeline
19751965 201119901985
1956: Series 1
implemented as fi rs t required exam
1963: Series 2 (SECO) implemented under
SEC Rule 15b8-1
1/1964: Series 12 implemented as
NYSE Branch Manager exam
1/1965: Series 16
implemented for NYSE Supervisory Analysts
9/1965: Series 40
implemented as supervisory exam for Branch Office
Managers
1/1970: Requirement
change - A candidate must hold the Series 2 registration for at least two years , to be
exempt from Series 1 requirement
9/1974: Series 7 implemented as
the General Securi ties
Registered Representative exam
1977: SEC
approves
MSRB rules to set forth
guidelines for qualification exams
3/1975: Series 7 replaces Series 1
as general securities exam.
Series 1 only
applicable to DPP and Investment
Company bus iness
4/1975: Series 4 implemented as
Options Principal Exam
4/1977: Put
options are added to Series 4
11/1978: State and municipal
content added to the Series 7
1/1979: Series 24 implemented as the General Securi ties Principal exam
4/1979: Series 40
reti red and replaced
with Series 24
6/1979: Series 26 implemented as the
Variable Products/ Contracts Principal exam
2/1980: Series 53
(MSRB) implemented as the Municipal Securi ties Principal exam
8/1980: Series 22 implemented as the
DPP exam _________________
Series 22 replaces the Series 1 as a prerequisite to the Series 39
11/1980: Series 54 (MSRB)
implemented as the Municipal
Securi ties FINOP
exam
12/1981: Series 5 implemented as
the Interest Rate Option Exam
9/1982: Series 15 implemented as
the Foreign Currency Options
exam
6/1988: Interest rate and foreign Currency
Options added to the Series 4
6/1989: Foreign
Current and Index Options are added to the Series 7
9/1989: Series 14
implemented as the NYSE Compl iance Official exam
1/1990: Series 11
implemented as the Ass istantRepresentative exam
4/1991: Series 12
reimplemented
as supervisory exam for floor
brokers
5/1995: IRT
scoring implemented for the Series 7
6/1995: Series 42 implemented as
the Registered Options
Representative
exam
4/1996: Series 38 implemented as
the Canadian Module (without
options) of the Series 7
9/1996: Series 2
i s retired
4/1998: Series 72 i s
implemented as the Government Securi tiesRepresentative exam_________________Series 72 is added as a prerequisite for the
Series 42
8/1999: Series 8 i s reti red
01/2000: Series 63, 65, and 66 (NASAA) adopt
waiting periods between failed exam attempts
10/2000:
Deadline for ini tial opt-in to the Series 55 registration
5/2001: Series 82
implemented as the Limited Representative -
Private Securities Offering exam (in response to Gramm-Leach-
Bl i ley Act of 1999)
1/2003: Series 51 (MSRB) implemented as the
Municipal Fund Securities Limited Exam
3/2004: Series 87
implemented as the Research Analyst Exam -Regulations
Module
11/2008: Series 15
i s retired
11/2009: Series 79
implemented as the Limited Representative -Investment
Banking exam
3/2010: Series 5
is retired
6/2011: Series 56 implemented as
the Proprietary Trader exam
10/2011: Series 99
implemented as the
Operations Professional exam
(SEC mandate in response to Bernie Madoff scandal)
11/2011: Series 7 i s no longer
accepted by the MSRB as an alter to the Series 52 ___________________Series 7 i s no longer an acceptable
prerequisite for the Series 53___________________
Moving forward, MSRB
mandates that individuals must pass the Series 52 to act as a
Municipal Securities Representative
12/2011: Deadline for member fi rms to identify
Day-One Operations Professionals (Series 99)
10/2012: Deadline
for Day-One Operations Professionals to obtain Operations
Professional registration (Series 99)
4/1984: Series
12 reti red since Series 8 covered same content
4/07: Series 12
reti red as content was duplicative of
Series 10
7/2012: Series 56 replaced
Series 44, 45, 48 and 49
5/2010: End of "opt in" period for
Series 79
3/2004: Series 86 implemented as
the Research Analyst exam-
Analysis Module
4/2003: Series 24 and 26 no longer accepted as qualifying registrations
for individuals that act as principals for municipal mutual funds activities
7/2003: Series 23 implemented as the General Securi ties Principal Sales
Supervisor module 8/1999: Series 9 and 10 are
implemented as General Securities
(and Options)
Supervisor exams
4/1998: Series 55 implemented as the
Limited Representative -
Equity Trader exam
4/1996: Series 37
implemented as the Canadian Module (with options) of the Series 7
7/1995: Series 66
(NASAA) implemented as the Uniform Combined State
Law exam
5/1995: Foreign
currency options,
interest rate options, and index options are added to the Series 8
5/1991: Series 17 implemented as
the Limited Registered
Representative
exam (UK), a subset exam of
the Series 7
1/1990: Series 28 implemented as the
Introducing Broker-Dealer FINOP exam
1/1990: Series 54 i s
reti red and replaced with the Series 27
9/1989: Series 65 (NASAA)
implemented as the Uni form
Investment Advisor Law exam
6/1988: Series 18 reti red
6/1988: Series 62 implemented as the
Corporate Securities Representative exam
12/1981: Series 8
implemented as the General Supervisory exam
7/2007: NASD and NYSE merge
to create FINRA
8/1980: Series 6 implemented as the
Investment Co. exam _________________
Series 6 replaces the Series 1 as a prerequisite to the Series 26
7/1980: Series 1
i s retired6/1979: Series 39
implemented as DPP Principal exam
4/1979: Series 63 (NASAA) implemented
as the Uniform Secs. Agent State Law Exam
1/1979: Series 27 implemented as the FINOP exam (result of retiring
Series 40)
11/1978: Series 52 (MSRB) implemented
as the Municipal Securi ties Registered
Representative exam
5/1977: Put options are
added to Series 7
6/1977: Series 7 i s added as a
prerequisite for the Series 40
4/1975: Cal l
options are added to Series 7
4/1973: CBOE
created
1975: MSRB created by act
of Congress
1956
3
Examination Implementation Timeline
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Restructuring of Qualification Exams
■ Continuing Education
• Introduction of CE Online – October 2015 and January 2016
• Projected Evolution of CE
– Availability via tablet, smartphone
4
Future
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Project underway to migrate the Regulatory Element Program to an
online, Web-delivered format
■ Conducted industry outreach to seek feedback
• Industry Focus Groups
• Firm Survey
■ Pilot test conducted July 21 - August 20, 2014
• 2,073 participants responded overwhelmingly positive to Web delivery of CE
• Participants completed a brief survey at end of pilot to provide feedback
■ Post-pilot analysis
• Follow up survey to firms
• Outreach to firms that were opposed to Web delivery
• Reviewed Call Center logs/mailbox questions/comments
• On-going conversations with CE Council and content committees
6
CE Online – Project Overview
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Tech Updates
■ Develop technology to support production implementation
• Use data and lessons learned from outreach and pilot test
■ Participant accesses CE Sessions through links on FINRA.org
and CECouncil.com
■ System check runs to verify supported browsers and versions
after clicking on link
• Will not be able to start session, if browser is not supported
■ Supported Browsers:
• Internet Explorer: Versions 9 and higher
• Firefox: Versions 20 and higher
• Chrome: Versions 27 and higher
• Safari: Versions 5 and higher (MAC only- no tablet support at this time)
■ Updated Captcha Software
7
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Firm Notifications
■ Automatic CRD messaging to firms re 120-day window status
continues
• CE Contacts continue to receive standard CRD CE alerts at 90/30/10 day
intervals and notice if an individual goes CE Inactive for not completing
within the 120-day window
■ CRD will allow firms to track candidates’ sessions
• Status of session - Will appear under “Appointment Status”
• Candidates must show proficiency in 4 modules
• Displays number of modules successfully completed
• Web Delivery will be listed under “Vendor
■ Report Center
• No anticipated changes to quarterly reports
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Advantages
9
■ Increased productivity - elimination of travel to test centers
• Advantages for both firms and candidates
■ No onerous test center security measures
■ Ability to access CE Online anytime/anywhere
– No session time restriction of 3.5 hours
– Candidate can satisfy requirement anytime within 120 day window
■ Bookmarking allows candidates to complete at their own pace
and return to last location in session
■ No requirements for firms to proctor sessions
• Flexibility as to amount of involvement/oversight
• WSPs may define where/when/how candidates take CE Online sessions
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Sessions
■ Participant clicks on link located on FINRA.org or CECouncil.com
to begin session
• Logs in using first name / last name / CRD #
• System randomly requests candidate to enter either
first 5 or last 4 of Social Security Number (SSN) and date of birth (DOB)
– SSN and DOB will NOT be stored
• Matched against CRD and discarded
• Responds to Captcha entry
• 30-minute lockout period if participant enters information incorrectly 3x
■ Acknowledges Data Privacy Policy
■ Agrees to Code of Conduct
■ Participant must enter firm email address to receive CE
completion certificate
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Open Sessions
■ Returning to session
• Participant skips verification if same user/machine (IP Address) within 3
hour window
• Session timeout after 30 minutes of inactivity
■ Participants can repeat modules until they show proficiency
• Participants cycle through cases in module until proficiency achieved
• Only repeat module(s) they are having trouble with
• No additional charges
■ Open session closes when CE window closes
■ CE Online session fee is charged at time of completion
■ For CE inactive reps
• Any open session will be closed at end of 120 days
• Will have to take entire session again
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Transitioning from Test Centers
■ Phase 1 (October 1, 2015)
• In-Firm Delivery sites transition began
• Participants access CE Online for S201/S106/S901 Programs
• S101 continues to be administered at test centers
■ Phase 2 (January 4, 2016)
• Participants can access CE Online for S101
– Personalized S101 content rolls out
• S501 retires as a program and is subsumed into Trading Module of
S101
– Complete In-Firm Delivery transitions
■ Phase 3 (June 2016)
• 100% of CE sessions completed on Web
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
CE Online – Communications Plan
■ Rule Filing Approved by SEC
• Changes to Rule 1250
– Removed language related to In-Firm Delivery sites
– Eliminated Proctor registration
– Fee for CE Online reduced to $55
– Regulatory Notice
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA 14
CE Online – Rollout Plan
Q2 2015 Q1 2015 Q1 2016 Q3 2015
S101 -
Personalization
Goes Live
Q4 2015
S106, S201,
S901 Programs
Go Live
Q2 2016 Q3 2016
*S501 Program
Merged into
S101 Program
100% Web
Delivery
Planning next generation of CE
Continue Communications to the Industry: Reg. Notice,
Rule Filing, Committee/Council Meetings, etc.
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Today’s Representative-Level Exams
Series 7
Series 6 Series 79
Series 42
Series 11
Series 55
Series 86
Series 87
Series 62 Series 72
Series 82
Series 99
Series 56
Series 17
Series 37 Series 38
Series 22
Series 99
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Respond to industry and regulatory changes
Reduce the redundancy of content across
exams
Streamline the exam process
Minimize impact and change to the registration
rules
Ensure registered reps have a solid breadth of
understanding of the industry
17
Qualification Exam Restructuring
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Revised Exam Structure
Essentials Exam
Series 6
Series 7
Series 22
Series 57
Series 79
Series 82
Series 86/87
Series 99
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Securities Industry Essentials Exam Content
■ Securities Industry Essentials Exam content would include
knowledge all securities industry registrants should understand,
including but not limited to:
–Structure and functioning of the securities industry
–Regulatory agencies and their functions
–Basic economics
–Product knowledge (stocks, bonds, mutual funds)
–Regulated and prohibited practices
–Professional conduct
Content would be largely stable and subject to little change over
time (i.e., the characteristics of products are constant)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
FINRA would introduce two new features for the Essentials Exam:
• A person would not need to be associated with a member firm to take the
Essentials Exam
• A passing score on the Essentials Exam would be valid for four years from
the date the person passes the exam
Passing the Essentials Exam alone would not qualify a person to
hold a registered position
20
Essentials Exam Eligibility
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Current:
Future/Proposed:
Example: Current vs. Future (Conceptual Illustration)
Path to Registered Representative Registration
General
Securities
Representative
+
Revised
Series 7
150
Questions
Essentials
Exam
100
Questions
General
Securities
Representative
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Series 11 Exam (Order Processing Assistant) – FINRA
considering the impact of retiring exam and registration category
■ Series 17/37/38 Exams – FINRA analyzing whether UK and
Canadian certifications have a high enough overlap of content
with the Essentials Exam to exempt certificate holders
■ FINRA would retire the Series 42 (Options Representative), Series
62 (Corporate Securities Representative), and Series 72
(Government Securities Representative) exams
22
Other Features of the Proposal
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Current representative-level registrants would maintain
registration without additional testing
■ Most current registrants would be considered to have passed the
Essentials Exam and it would be valid for 4 years upon leaving
the industry
• If the registrant returns within 2 years, she would regain registration without
the need to take the Essentials or top-off exam
• If the registrant returns between 2 and 4 years later, she would not need to
take the Essentials Exam, only the top-off exam for the registration position
• If the registrant returns more than 4 years later, she would need to take
both the Essentials and the top-off exam
23
Effect on Current Registrants
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ New exam structure will give firms an opportunity to employ new
business models for onboarding staff
■ Targeted training for Essentials and top off exams will allow reps
to gain a more thorough understanding of products and
associated rules
■ Allowing non-registered staff (e.g., administrative, back office) to
take Essentials Exam will help them gain a better understanding
of the securities industry
■ With current rep population aging, new exam structure will create
a larger pool of potential new reps
24
Industry Opportunities
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Published May 27, 2015, with a 60 day comment period
■ FINRA received 20 comment letters – almost all commenters
support the proposal
■ Commenters believe proposal will make exam program less
burdensome, less costly and more efficient
■ Commenters support 4 year validity period for Essentials exam –
some suggest a 5 or 6 year period of validity
■ Commenters support retiring exams which have lost utility
25
Regulatory Notice 15-20 Concept Release
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Many commenters believe allowing non-firm associated persons
to take the Essentials will encourage younger people to come
into the securities industry
■ A few commenters expressed concern that persons who pass
only the Essentials may hold themselves out to public as
qualified to do business
■ Content on Essentials exam should be tailored to test concepts
at an appropriate level
26
Regulatory Notice 15-20 - Comments
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
■ Present proposal to FINRA Board for approval to file with SEC
■ Make registration rule, fee and qualification exam filings with the
SEC in early to mid 2016
■ Implement Essentials and top off exams in early 2017
■ FINRA is looking at principal level qualification examination
program to identify an opportunity for restructuring
27
Next Steps
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
TEST SECURITY An Overview
Questions
28
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Topics of Discussion
■ Review of the 2015-2016 Registration & Disclosure (RAD) Program
Roadmap
• Web CRD, Investment Adviser Registration Depository (IARD), BrokerCheck
and Investment Adviser Public Disclosure (IAPD)
■ 2015 RAD System Highlights
■ What’s Next?
■ 2016 Renewal Program
■ User Testing
30
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
2015 – Q2 2016 RAD Program Roadmap
Q4 2015 Q1 2016 Q3 2015 Q2 2016
Web CRD, IARD, and PFRD Release 2015.09 (September 12, 2015) • Modernize system
functionality that is associated with individual form filings
• Support mixed-case data entry on all individual filings
• Allow firms to upload U4/U5 DRPs through Web EFT
• Weekend CRD processing
BrokerCheck Release 2015.10 (October 24, 2015) • Implement a “What’s
New” Banner/Alert
Public Disclosure programs
Registration programs
Web CRD, IARD, and PFRD Release 2015.10 (October 24, 2015) • New Form U4
completeness checks Form U4 and report functionality to safe guard personal identifying information
• New Back Office fingerprint email notifications
• Minor bug fixes
Web CRD, IARD, and PFRD Release 2016.04 (April 2016) • SEC-mandated
updates to Form PF • State and industry
enhancements • Minor bug fixes
IAPD Release 2016.01 (December 2015) • Usability
Enhancements • IAPD mobile-
compatibility
BrokerCheck and IAPD Quarter Release (TBD) • BrokerCheck usability
enhancements (TBD)
31
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Online Snapshot
■ Former FINRA registered representatives were given the ability to
update their CRD residential information via the Online Snapshot
site
■ The Online Snapshot was enhanced to include an individual’s
most recent answers to the Form U4 Disclosure Questions
(Section 14)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Form U4 – Change Office of Employment End Date
■ Firms were given the ability to submit a Form U4 Amendment
filing to change Office of Employment end dates in the General
Information section of Form U4 (Section 1)
• Select Edit
34
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Form U4 – Change Office of Employment End Date
(cont.)
■ Provide updated End Date details
35
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Form U4 – Create CRD Records for Foreign Associates
■ Firms were given the ability to create CRD records for individuals
(foreign associates) who do not have a Social Security Number
(SSN)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
DRPs – Completeness Check Changes
■ A Judgment/Lien Disclosure Reporting Page (DRP) completeness
check was relaxed to allow users to file a DRP when the date the
individual learned of the lien (question 4.b.) is a more recent date
than the disposition date (question 7.a.). However, a warning
message will display advising users to review/confirm the dates
provided.
■ The Bankruptcy Disclosure Reporting page (DRP) allows users to
file a new DRP for an event that is already beyond 10 years.
37
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
DRPs – New URL Field added for Reg Actions
■ State users were given the ability to add a URL to Regulatory
Action DRPs that will link to the Internet posting of the
enforcement action(s) filed by the reporting jurisdiction
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
NRF – Auto Populate Billing Code
■ Firms were given the ability to auto-populate the office of
employment address based on Billing Code for all Non-
Registered Fingerprint (NRF) filings
■ NOTE: This enhancement is consistent with functionality that is currently
available for registered reps on section 1
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
NRF – Amend Termination Dates
■ Firms were given the ability to amend Non-Registered Fingerprint
person (NRF) termination dates
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
View Individual – Taping Rule 3170
■ An indicator was added to the following sections of the Pre-hire
and Regular View Individual pages for individuals that are
currently or have previously been registered with disciplined
firms:
• Registrations Summary
• Registrations with Current Employers
• Registrations with Prior Employers
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
View Individual – Taping Rule 3170 (cont.)
■ Firms were provided with the ability to request a new Taping Rule
Report that identifies any of their representatives that have
previously been registered with a disciplined firm
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
View Individual – Taping Rule 3170 (cont.)
■ The Individual Snapshot report was enhanced to indicate when
individuals have previously been registered with a disciplined
firm
■ This field is visible to firms users
43
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Web CE Delivery
■ Updates were made to CRD to accommodate Web delivery of the
CE Regulatory Element
• Note: Online delivery of the S106, S201& S901 began on October 1, 2015.
Delivery of S101 begins on January 4, 2016.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Web CRD, IARD & PFRD Session Timeouts
■ The session timeout for Web CRD, IARD and PFRD was reduced
to 30 minutes.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Other Web CRD Highlights
Impacted Area Description of Change
Printer-Friendly When using the Printer Friendly option in Web CRD, the
font size on the printout will be increased.
47
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms
■ Extensive behind-the-scenes work was done to modernize the
CRD individual form filing code base. Impacted forms are:
• U4
• U5
• NRF
• Individual U6
■ As a result, users now experience several look-and-feel upgrades
while completing forms online
• The Web EFT form filing schemas were also rewritten, including adding the
ability to upload DRPs via XML for the first time
■ This release prepares us for the eventual individual forms rewrite
on the long-term roadmap
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ Web CRD was updated to no longer automatically convert text
entered on individual forms to all capital letters. The system will
preserve the case as entered by the user.
• Firms are not required to go back and resubmit previous filings in mixed
case. It is understood that we will have mismatched records for some time.
Current version:
New version:
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ All country and state free text fields have been converted to
dropdown boxes with a standard list of values
• Where possible, existing state and country data will be mapped to the
corresponding dropdown value
■ Specifically for U4 Section 9, the ‘State/Province of Birth’ text
field was split into two separate drop-down boxes
• Filers will be required to complete either one field or the other, not both
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ Entries on sections that contain multiple list items have been
added or edited in re-sizeable pop-up windows, not new browser
pages
■ Postal codes entered must now be valid for the state selected
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ Upgraded calendar controls are now available on long date fields
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ Links were added for the individual Disclosure Reporting Page
(DRP) categories that display on the main form navigation panel
Current version: New version:
54
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ The 'Not on List' option in the state dropdown in the Customer
Complaint DRP was replaced with the value 'N/A'
Current:
New:
55
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Individual Forms (cont.)
■ The print preview function on pending U4, U5 & NRF filings now
includes a redline mode to further assist users with identifying
changes from the previous filing
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Weekend CRD Processing
■ The frequency of nightly Web CRD processing jobs was
increased to run after system shutdown on Fridays. This
includes:
• Accounting processing
• Organization Termination processing
• Firm Notifications
• Web EFT Daily reports
■ Now updated data and notifications are available on Saturday,
rather than waiting until Monday.
57
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
BrokerCheck – Initial Launch
■ BrokerCheck continues to evolve from its initial launch in 2007.
59
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
BrokerCheck - Enhancements
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
BrokerCheck – Now
■ In 2015 BrokerCheck went through a significant redesign
• Search functionality was revamped and optimized to be more effective
• Summary pages were reorganized to make information easier to read
and understand
• Disclosure events, years of experience, qualifications, and current
registration information is clearly displayed
■ The redesign was accompanied by a nationwide multi-
media campaign (print, Web and television)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
BrokerCheck – Now (cont.)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Web CRD Release 2015.10 – Go-Live October 24, 2015
Impacted Area Description of Change
Individual Forms • Add checks to Form U4 to ensure SSN is not provided in
Bankruptcy/Judgment Lien –Docket Case# field (if PII
checkbox is not selected) & U4 Other Business field
• Display an alert on the Form U4 jurisdictions registrations
page when firms select the Mark All AG box to prevent users
from erroneously selecting all jurisdictions and paying
associated fees(CIFER 247)
Reports • Add PII Terms& Conditions to all the CRD & IARD reports –
includes adding the T&C when you elect to View a report and
also within the report
Notifications • Include back office individuals in fingerprint related email
notifications
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Upcoming Changes
Description of Change Targeted Release Go-Live
• Allow staff to manually upload RAPP sheets
and send notifications to firms/regulators
December 2015
• IAPD Usability Enhancements
• Modernize the interface
• Make the application mobile-compatible
January 2016
• Hold AG approvals until Fingerprint results
are posted on Web CRD
April 2016
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
2016 Renewal Highlights
■ Preliminary Statements become available on November 16, 2015
■ Full payment is due Friday, December 18, 2015
■ Detailed information is available at: www.finra.org/renewals
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
User Testing
■ What is user testing?
• Current users volunteer to test new and changed system features before
they are implemented
• Participants are required to already have production access to the system
they would like to test
■ Why participate?
• Gain a better understanding of what is changing in an upcoming release
• Have an opportunity to provide your feedback
■ If you are interested, send your name and Firm CRD number to:
Application Contact
Web CRD and IARD [email protected]
Web EFT [email protected]
PFRD [email protected]
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
TEST SECURITY An Overview
■ Testing and Measurement Brown Bag
Session
■ December 2013
Questions
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Resources for Firms
■ Firm Gateway
■ Compliance Resource Provider Program
■ FINRA Conferences
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Firm Gateway Enhancements
1
2
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
User Feedback Community
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
User Feedback Community
■ Firms can sign up to give feedback on FINRA systems
■ Benefits
• Firms view beta (test) versions of enhancements
• Firms give early feedback on new systems/features
• Provides firms training on new systems/features
• Firms ability to participate in User Testing
■ Provides FINRA teams the opportunity to hear feedback directly
from the firms who use these systems every day
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
FINRA Systems Information Page
Firm Gateway
System Hours: 5am-11pm, EST Mon- Sun
Call Center: 1-800-869-6699
Online Resources
User Administration
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-301-836-6699
Online Resources
Systems: Enterprise Web Security (EWS)
Information Requests
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-800-321-6273
Online Resources
Systems
E-Bill
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-301-869-6699
Online Resources
Firm Profile
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-800-321-6273
Online Resources
Systems: FINRA Contact System
OATS
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-800-321-6273
Online Resources
Report Center
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-301-869-6699
Online Resources
IARD
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-240-386-4848
Online Resources
Web CRD
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-301-869-6699
Online Resources
Systems: Web CRD and Web EFT
Forms & Fillings
System Hours: 7am-9pm, EST Mon-Sun
Call Center: 1-800-321-6273
Online Resources
Systems
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Welcome to the new Systems Information Page
This page displays details on the systems and filings available via the Firm
Gateway including system availability and online resources
FINRA Call Center Support Hours: 8AM-8PM (ET) Monday-Friday
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
FINRA Compliance Resource Provider Program
■ FINRA works with the following organizations to offer FINRA
firms discounts on products and services that help them comply
with securities laws and regulations
• Message Archiving-Global Relay
• Disclosure Monitoring Services-Business Information Group (BIG)
• Electronic Fingerprint Submission- BIG
• Insurance Program- Mercer Consumer
• Next vendor-TBD
www.finra.org/complianceresourceproviders/
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
FINRA Conferences
■ FINRA Small Firm Conference-NEW
• November 11-12, 2015
• Santa Monica, CA
■ FINRA Cybersecurity Conference-NEW
• February 11, 2016
• New York, NY
■ FINRA Annual Conference
• May 23-25, 2016
• Marriott Marquis, Washington DC
http://www.finra.org/Industry/Education/ConferencesEvents/
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
FINRA Conferences
■ Two ways to participate
• In Person
• Live Video Broadcast
■ Mobile App available for In Person and Live Video Broadcast
• Event Schedule
• Panel Description and Materials
• Interactive Map
• Speakers & Bio
• Attendees
• Ask A Question
• Exhibitors
• Survey
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Questions
Karrie Foley, Vice President
Member Relations and Education
(301) 509-5442
83
©2015 Financial Industry Regulatory Authority (FINRA). All rights reserved. Materials may not be reprinted or republished
without the express permission of FINRA. Individuals, firms and data mentioned in these materials are fictitious and are
presented exclusively for purposes of illustration or example.
2015 SILA National Education Conference
FINRA Registration & Disclosure Public Records Review,
Statutory Disqualification and BrokerCheck Updates October 5, 2015 • Nashvillle, TN
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Topics of Discussion
Public Records Cross-Check Validation Project
Registered Representative Snapshot Feature
FINRA Rule 3110(e)
Late Filing Fee Relief
Current Status Public Records Cross-Check Validation
Statutory Disqualification
BrokerCheck Update
Questions
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Public Records Cross-Check Validation History
• Data contained in CRD, which are derived from uniform forms, rely
largely on a self-reporting model.
• Certain ‘checks and balances’ do exist, such as CHRI obtained from
fingerprinting upon hire, arbitrations filed in FINRA’s Dispute
Resolution and FINRA regulatory proceedings.
• RAD conducted an informal survey and learned that most firms were
conducting background checks prior to submitting Forms U4.
• Firms generally must rely on the registered representative (RR) to
make disclosure of events (such as criminal, bankruptcies and
judgments/liens) that occur post-hire.
• While many firms periodically (e.g., quarterly, semi-annually or
annually) send questionnaires to RR inquiring about these events, in
these cases the firm is also relying on the RR to self-report.
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Public Records Cross-Check Validation History
• April 2014 – FINRA announced that it is searching public financial
records for all RRs to validate that bankruptcy filings and outstanding
judgments or liens are appropriately reported. In addition, criminal
public records will be searched for any RR not fingerprinted in the last
5 years.
• July 2014 – While we were seeking a public records data aggregator
(vendor) to do a bulk file comparison, RAD began sending one-at-a-
time letters requesting updated disclosure based on public records
findings.
• September 2014 – Separately, FINRA launched the RR Snapshot
feature. RRs can now obtain their own snapshot reports directly. The
link is on the FINRA website: www.finra.org/snapshot.
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RR Ability to Validate His/her Own CRD Record
In FINRA’s Weekly email to Executive Reps, firms were advised to
communicate the existence of this feature to their RRs and asked that their
RRs periodically validate the information in their CRD records.
Note: Due to the terms and conditions of use, firms should not utilize this
RR Snapshot feature.
– For current employees: firms should use CRD,
– For prospective employees: firms should utilize the pre-registration
feature through which the firm acknowledges that it has permission from
the prospective RR to view his/her CRD record.
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Registered Representative Snapshot Feature
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Registered Representative Snapshot Feature
(cont.)
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Public Records Cross-Check Validation History
• December 2014 – RAD contracted a vendor for financial disclosures (e.g.,
bankruptcies, judgments, liens) and provided the vendor with the names,
Social Security numbers, CRD numbers and home addresses of all active RRs
to identify individuals resulting in a hit.
• First Quarter 2015 – Once we identified those resulting in hits, RAD compared
that information against CRD and filtered out matters already reported and
those that were never reportable, such as bankruptcies older than 10 years old
when the individual entered the industry, as well as judgments and liens that
were satisfied prior to the RR joining the industry.
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Public Records Validation Requirement
December 2014 – SEC approved FINRA Rule 3110(e) effective July 1,
2015 requiring firms to:
• Ascertain by investigation the good character, business reputation,
qualifications and experience of an applicant
• Review a copy of the applicant's most recent Form U5
(or NFA Termination Notice Form 8-T, if applicable) within 60 days
• Establish and implement Written Supervisory Procedures (WSPs)
reasonably designed to verify the accuracy and completeness of the
information contained in an applicant's initial or transfer Form U4 within 30
days
– WSPs must, at a minimum, provide for a search of reasonably available
public records to be conducted by the member (or a third-party) to verify
the accuracy and completeness of the information on the U4.
In March 2015, FINRA Publishes Regulatory Notice 15-05 announcing
the rule.
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Public Records Cross-Check Validation History
• April 2015 – RAD began sending notices to firms in bulk. Each RR who may have an undisclosed event will have an individual disclosure letter in his/her CRD record for tracking purposes. Large firms with numerous potential unreported financial disclosures were provided letters through the Disclosure Letter Queue along with rosters available in Excel spreadsheet format for ease of sorting and filtering.
• April and May 2015 – RAD hosted a series of conference calls with firms that were impacted by the public records initiative. The calls provided firms with (1) background, (2) tools provided to the firms to assist with this initiative, (3) correspondence, in lieu of disclosure, (4) refunds, credits and adjustment of late disclosure fees, and (5) additional resources. The calls also provided a venue for firms to vet any questions they might have.
• June 2015 – For those unable to participate on the calls and as an extra resources, RAD published a document titled “CRD Public Records Validation Initiative.” That document, which can be found on FINRA.org, provides the aforementioned information and addressed the questions raised on the conference calls.
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Public Records Validation - Late Fee Relief
Temporary relief of late filing fees will be provided for unsatisfied
judgments or liens (14M) for filings submitted between April 24, 2014
through December 1, 2015, if one of the following conditions is met:
– (1) the judgment or lien has been satisfied, and at the time it was
unsatisfied, it was under $5,000 and the date the judgment or lien
was filed with a court was on or before August 13, 2012; or
– (2) the unsatisfied judgment or lien was satisfied within 30 days after
the individual learned of the judgment or lien.
This temporary relief of certain late filing fees is provided pursuant to
FINRA Rule 3110.15, which became retroactive effective April 24, 2014
and sunsets on December 1, 2015.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Public Records Validation - Late Fee Relief (cont.)
In addition, RAD will also refund Late Disclosure fees if the reporting
obligation resided with a previous employer (i.e. the RR had an
unreported lien that was satisfied before he/she joined their current firm).
In situations where the judgment/lien was more than $5,000 and satisfied
before January 2, 2013, RAD will assess the previous maximum Late
Disclosure fee of $300 (instead of the current $1,575).
RAD is proactively screening for filings that qualify for the late fee refund
and issuing those refunds automatically. Credit to a firms flex-funding
account usually takes 1 week. Firms can validate the credits by checking
the standard report “Accounting – Late Disclosure Fee Report and
Download.”
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Public Records Cross-Check Validation Current
Status
• RAD has completed the review of public records for both unreported financial
and criminal matters and has reached out to all impacted member firms for
disclosure. As a result, RAD is in the data-collection mode. Firms are
submitting either Form U4 amendments to report the event or providing written
explanation and/or documentation why the RR believes it is not reportable.
• Once RAD completes initial searches, RAD will continue to conduct periodic
reviews of public records to ascertain the accuracy and completeness of the
information available to investors, regulators and firms.
• Egregious under reporting may warrant referral for additional regulatory
review.
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Resources
Individual Snapshot Reports Now Available Online – Information Notice (September 25, 2014) http://www.finra.org/industry/information-notice-092514
FINRA Rule Regarding Background Checks (Regulatory Notice 15-05) http://www.finra.org/industry/notices/15-05
CRD Public Records Validation Initiative http://www.finra.org/sites/default/files/CRD-PublicRecordsValidationInitiative_June.16.pdf
Late Disclosure Fee http://www.finra.org/industry/faq-late-disclosure-fee-frequently-asked-questions
CRD Filing Guidance & Policy page: http://www.finra.org/industry/crd/filing-guidance
Form U4 and U5 Interpretive Questions and Answers (Disclosure)
Disclosure Inquiry Letter Tracking Frequently Asked Questions (FAQ)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
TEST SECURITY An Overview
Questions
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Overview of Statutory Disqualification
Article III, Section 3 of FINRA's By-Laws provides that no member shall be
continued in membership if it becomes subject to disqualification; and
that no person shall be associated with a member, continue to be
associated with a member, or transfer association to another member if such
person is or becomes subject to disqualification.
Article III, Section 3(d) of FINRA's By-Laws permits a disqualified person or
member to request permission to enter or remain in the securities industry.
FINRA Rules 9520 through 9527 set forth procedures for a member to
sponsor the proposed association of a person subject to disqualification or for
a member to obtain approval to remain a member notwithstanding the
existence of a disqualification. These actions are referred to as "Eligibility
Proceedings."
Generally speaking, a person who is subject to disqualification may not
associate with a FINRA member in any capacity unless and until approved in
an Eligibility Proceeding.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Disqualification Defined
Article III, Section 4 of the By-Laws states that a person is subject to a
"disqualification" with respect to membership, or association with a member, if
such person is subject to any "statutory disqualification" as such term is
defined in Section 3(a)(39) of the Exchange Act.
Historic disqualifying events include: expulsions, denials, revocations, bars, and suspensions ordered by the SEC, the Commodity
Futures Trading Commission (CFTC), registered futures associations, foreign financial regulators, or self-regulatory organizations (SROs), Exchange Act § 3(a)(39)(A)-(B); a finding that the person was the cause of such expulsion, denial, revocation, bar, or suspension. Exchange Act § 3(a)(39)(C)-(D); or association with any person subject to such an event. Exchange Act § 3(a)(39)(E).
a finding that a member or person has “willfully” made certain false statements in applications or reports made to, or in proceedings before, an SRO (Exchange Act § 39a)(39)(F)) or foreign financial regulatory authority. Exchange Act §3(a)(39)(F) incorporating § 15(b)(4)(G).
certain foreign felony and misdemeanor, and all domestic felony, convictions for a period of ten years from the date of conviction. Exchange Act § 3(a)(39)(F) incorporating § 15(b)(4)(B).
temporary and permanent injunctions (regardless of their age) issued by a court of competent jurisdiction involving a broad range of unlawful investment activities. Exchange Act § 3(a)(39)(F) incorporating § 15(b)(4)(C).
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Expanded Definition of Statutory Disqualification
In 2009, FINRA adopted a revised definition of “disqualification” to conform to
the definition of “statutory disqualification” under Section 3(a) (39) of the
Exchange Act.
As a result, FINRA’s revised definition now incorporates the following three
additional categories of disqualification:
Willful violations of the federal securities or commodities laws, including failure to
supervise
Events added by the enactment of the Sarbanes-Oxley Act of 2002 (Sarbanes-
Oxley Act)
– Bars
– Final Orders with Fraud, Manipulative, Deceptive Conduct
Certain affiliated relationships (associated persons)
– any person directly or indirectly controlling, controlled by, or under common control with such
member, or an employee of such member.
– The term “person” means a natural person, company, government, or political subdivision,
agency, or instrumentality of government.
2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
FINRA Registration and Disclosure’s Role
RAD staff:
Identifies persons (both individuals and firms) who are subject to
statutory disqualification under FINRA By-Laws, and determines
whether an eligibility proceeding is required.
Notifies the firm of the disqualification and requests that the firm:
file a membership continuance application (MC-400 to sponsor an individual
or MC-400A to sponsor itself); or
In certain instances provide evidence that an application is not required; or
terminate the individual’s association with the firm; or
file a Form BDW to terminate its own registration.
Revokes registrations of individuals, if any, and cancels firm
memberships, where there is no response to the notice of
disqualification. FINRA Rule 9522(a)(2) & (3).
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FINRA Member Regulation’s Role
Member Regulation is responsible for the following:
Evaluating the MC-400 and MC-400A Applications, for the purposes
of making a recommendation or final determination;
Preparing the written recommendations or final determinations;
Negotiating the terms and conditions of the plans of heightened
supervision – which is a requirement for disqualified individuals;
Representing Member Regulation in SD hearings - in cases where
Member Regulation is recommending approval or denial of the
application to the SD Committee; and
Notifying the SEC of decisions to allow a disqualified person to
associate with a FINRA member or to permit a disqualified firm to
continue in membership with FINRA.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Statutory Disqualification Tiers
Tiers are risk assessment tools used for FINRA examination
purposes.
Tier I - Generally is assigned to firms/individuals subject to disqualification due to criminal or
regulatory actions involving violations of financial laws or regulations, theft (or analogous
misconduct), or the provision of false information.
Tier II - Generally is assigned to those subject to disqualification as a result of a domestic
felony conviction not covered under Tier I, for example felony drunk driving.
Tier III - Consists of those subject to disqualification who do not require special approval or
supervision. There are no special examination requirements associated with this Tier.
Members, and members associated with individuals, in Tiers I and II are subject to periodic
examinations, and to other examinations as FINRA staff deems appropriate.
Pursuant to its By-Laws, FINRA will assess a member $1,500 annually if it employs a person
in Tier I and $1,000 annually if it employs a person in Tier II.
More information about Tiers can be found on FINRA’s website at:
http://www.finra.org/sdprocess
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
SD Status Codes & Tiers
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
Municipalities Continuing Disclosure Corporation Initiative
(“MCDC Initiative”)
Arose out of an initiative by the SEC relating to the collective failures of firms acting as
underwriters of municipal securities offerings to conduct adequate due diligence in
determining whether the issuers of such securities substantially complied with their
continuing disclosure obligations pursuant to Rule 15c2-12 of the Exchange Act.
Cooperation Initiative (“MCDC Initiative”), the SEC offered certain settlement terms to
any underwriter that self-reported to the SEC its involvement in an offering where the
issuer of that offering failed to abide by its continuing disclosure requirements pursuant
to Exchange Act Rule 15c2-12.2
Based on these failures, the SEC found that the Firms willfully violated the antifraud
provisions of the federal securities laws, specifically Section 17(a)(2) of the Securities
Act, by offering and selling municipal securities on the basis of materially misleading
disclosure documents.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
MCDC Initiative
Pursuant to the Orders, Firms were fined between $60,000 and $250,000, and
each was required to comply with an identical set of undertakings.
Approximately 75 - 100 member firms will be required to file MC-400
Applications for MCDC
Three Phases
First Tranche - June/July
– FINRA’s processed 35 SD firms
Second Tranche – September/October
– FINRA processing 18 SD firms
Third Tranche – Late December
– SD Firms - TBD
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
RAD High Level Processing Overview - MCDC MC-400
Applications
SEC issued Order and are posted to SEC.gov
RAD SD Analyst obtains document and performs SD
review
RAD SD Analyst drafts/mails the MC-400 Notification letter via certified mail
and email to the firm’s Contact Employee
(approximately 2 day turn-around time)
Upon receipt of MC-400 application the RAD SD Analyst will verify that the application is
complete and compile the application.
RAD SD Analyst will forwarded the application to FINRA Member Regulation and mail a copy
to the firm.
(approximately 4 day turn-around time)
Member Regulation reviews the application and files 19H-1 notices
with the SEC
(approximately 1 – 2 months from order date)
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
MCDC Initiative
FAQs have been posted to FINRA.org
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
BrokerCheck
As part of FINRA’s ongoing effort to make BrokerCheck
information more visible and easier for investors to access, the
existing page content has been organized into a new layout.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
BrokerCheck
Between 2013 and 2014, RAD had focused much attention on moving pertinent information from the detailed report onto the summary page so that investors utilizing the tool can immediately get a good sense of the broker’s credentials – experience, disclosure, employment and registration.
FINRA engaged an outside vendor to assist with BrokerCheck’s “look & feel” with added icons and graphics, so that navigating through the tool was easy and intuitive.
FINRA launched two month-long advertising campaigns (June 2015 and September 2015) to expand our mission of investor protection. We are promoting BrokerCheck to the public as an indispensable, free tool to obtain critical information about brokers and firms.
The advertisements appeared on cable television with four different 15-second spots. The cable channels include CNBC, CNN, the Discovery Channel and ESPN. A print ad ran in The Wall Street Journal, while digital banner ads were featured on the leading financial news websites, including Bloomberg, CNN/CNN Money, CNBC, Forbes, Fortune, Reuters and WSJ.com.
The campaign was financed by a portion of the fines FINRA collected last year.
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2015 SILA National Education Conference October 2015 Copyright 2015 FINRA
TEST SECURITY An Overview
Questions
116
©2015 Financial Industry Regulatory Authority (FINRA). All rights reserved. Materials may not be reprinted or
republished without the express permission FINRA. Individuals, firms and data mentioned in these materials are
fictitious and are presented exclusively for purposes of illustration or example.