2015 broker/dealer compliance calendar

17
2015 Broker/Dealer Compliance Calendar Financial Registrations, Inc. 25602 Alicia Parkway #107 Laguna Hills, CA 92653 Toll-free (800) 641-1818 www.financialregistrations.com Moving Forward

Upload: scott-tarra

Post on 21-Jul-2016

219 views

Category:

Documents


4 download

DESCRIPTION

 

TRANSCRIPT

Page 1: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Financial Registrations, Inc. 25602 Alicia Parkway #107

Laguna Hills, CA 92653 Toll-free (800) 641-1818

www.financialregistrations.com

Moving Forward

Page 2: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 2 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Update: January 31, 2015 By Scott P. Tarra Managing Principal [email protected]

This 2015 Compliance Calendar is intended to inform FINRA member broker/dealers about compliance reporting requirements and filing deadlines as well as provide information on market holidays and events that may affect broker/dealer operations. This calendar is divided into two categories: compliance reporting and filing deadlines that are established on a calendar year basis and event driven requirements that are set internally by each firm based on previous year’s completion dates. While this calendar is intended to be used as a guide and reference when preparing and planning your annual compliance program, we encourage each firm to review its specific needs to determine the applicability of such requirements. As federal, state and SRO rules and regulations are subject to change, information on specific requirements as provided in this calendar should be verified to ensure compliance with current regulatory reporting guidelines.

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

Event Driven Tasks (based on previous year's completion date)

TBD

AML Continuing Education Training AML Annually AMLCO

TBD

Firm Element Continuing Education Training Education & Training Annually CCO/DSP

TBD

Annual Compliance Meeting(s) Education & Training Annually CCO/DSP

TBD

OSJ Main Office Compliance Review(s) Branch Supervision Annually CCO/DSP

TBD

OSJ Branch Office Compliance Review(s) (if applicable) Branch Supervision Annually CCO/DSP

TBD

Non-OSJ Branch Office Compliance Review(s) (if applicable) Branch Supervision Annually CCO/DSP

TBD

Independent Test of Anti-Money Laundering (AML) Program AML Annually AMLCO

TBD

Rule 3120/3130 Annual Test & Review Supervisory Controls Annually CCO/DSP

TBD

Rule 3130 Annual CEO Certification Supervisory Controls Annually CEO

Date Driven Tasks (based on Calendar Year due dates)

01/01/15 New Year’s Day Market Holiday Annually

01/04/15 2015 Final Renewal Statement Availability Renewals Annually FINOP

01/07/15

Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal

01/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

01/15/15

Quarterly Reporting of Customer Complaints (Quarter End December 31, 2014) Regulatory Reporting Quarterly CCO

01/16/15

Deadline for receipt of Final Renewal Statement payments Renewals Annually FINOP

Page 3: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 3 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

01/19/15 Martin Luther King, Jr. Day Market Holiday Annually

01/20/15

Short-Interest Reporting Deadline (Settlement Date of January 15, 2015) Financial Reporting Bi-Weekly FINOP

01/20/15

Automatic Transfers for 2015 Final Renewal Statement Payments Renewals Annually FINOP

01/27/15

Annual Schedule I Filing (for FYE December 31, 2014) Financial Reporting Annually FINOP

01/27/15

Quarterly FOCUS II/IIA Filing (Quarter End December 31, 2014) Financial Reporting Quarterly FINOP

01/27/15

Form Custody (Quarter End December 31, 2014) Financial Reporting Quarterly FINOP

01/27/15

Complete Monthly Financials and Net Capital Calculation (Period End December 31, 2014) Financial Reporting Monthly FINOP

01/27/15

Annual Contact Verification for FINRA and MSRB firms (FCS) Regulatory Reporting Annually CCO

01/27/15

MSRB Form A-12 Annual Affirmation (formerly MSRB G-40; MSRB Member Firms) Munis. Annually Muni Principal

01/29/15

Annual Audit Report (for FYE November 30, 2014) Financial Reporting Annually FINOP

01/30/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End December 31, 2014) Financial Reporting Monthly FINOP

01/30/15

Supplemental Statement of Income (SSOI) (Quarter End December 31, 2014) Financial Reporting Quarterly FINOP

01/31/15

MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal

01/31/15

Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader

01/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

02/03/15

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending December 31, 2014) Financial Reporting Quarterly FINOP

02/03/15

Short-Interest Reporting Deadline (Settlement Date of January 30, 2015) Financial Reporting Bi-Weekly FINOP

02/09/15

Customer Margin Balance Form Filing (Period End January 31, 2015) Financial Reporting Monthly FINOP

02/12/15

Annual Entitlement User Accounts Certification Process (for SAA) Regulatory Reporting Annually CCO

02/15/15 Month-end Compliance Review & Recap (month-end January 31, 2015) Supervision Monthly CCO/DSP

02/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

02/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

02/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

02/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

Page 4: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 4 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

02/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

02/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

02/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

02/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

02/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

02/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

02/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

02/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

02/16/15 President’s Day Market Holiday Annually

02/18/15

Short-Interest Reporting Deadline (Settlement Date of February 13, 2015) Financial Reporting Bi-Weekly FINOP

02/25/15

Monthly and Fifth FOCUS II/IIA Filing (Period End January 31, 2015) Financial Reporting Monthly FINOP

02/25/15

Complete Monthly Financials and Net Capital Calculation (Period End January 31, 2015) Financial Reporting Monthly FINOP

02/28/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

03/02/15

SIPC-7 General Assessment Reconciliation Filing and Payment (for firms with December 31st FYE) Financial Reporting Bi-Annually FINOP

03/02/15

Annual Audit Report (for FYE December 31, 2014) Financial Reporting Annually FINOP

03/02/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End January 31, 2015) Financial Reporting Monthly FINOP

03/03/15

Short-Interest Reporting Deadline (Settlement Date of February 27, 2015) Financial Reporting Bi-Weekly FINOP

03/09/15

Customer Margin Balance Form Filing (Period End February 27, 2015) Financial Reporting Monthly FINOP

03/15/15 Month-end Compliance Review & Recap (month-end February 28, 2015) Supervision Monthly CCO/DSP

03/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

03/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

03/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

03/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

03/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

Page 5: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 5 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

03/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

03/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

03/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

03/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

03/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

03/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

03/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

03/17/15

Short-Interest Reporting Deadline (Settlement Date of March 13, 2015) Financial Reporting Bi-Weekly FINOP

03/24/15

Monthly and Fifth FOCUS II/IIA Filing (Period End February 28, 2015) Financial Reporting Monthly FINOP

03/24/15

Complete Monthly Financials and Net Capital Calculation (Period End February 28, 2015) Financial Reporting Monthly FINOP

03/27/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End February 28, 2015) Financial Reporting Monthly FINOP

03/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

04/01/15

Annual Audit Report (for FYE January 31, 2015) Financial Reporting Annually FINOP

04/01/15

FINRA Gross Income Assessments (GIA) through E-Bill Financial Reporting Annually FINOP

04/02/15

Short-Interest Reporting Deadline (Settlement Date of March 31, 2015) Financial Reporting Bi-Weekly FINOP

04/03/15 Good Friday Market Holiday Annually

04/07/15

Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal

04/09/15

Customer Margin Balance Form Filing (Period End March 31, 2015) Financial Reporting Monthly FINOP

04/15/15 Month-end Compliance Review & Recap (month-end March 31, 2015) Supervision Monthly CCO/DSP

04/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

04/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

04/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

04/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

04/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

Page 6: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 6 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

04/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

04/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

04/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

04/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

04/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

04/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

04/15/15

Quarterly Reporting of Customer Complaints (Quarter Ending March 31, 2015) Regulatory Reporting Quarterly CCO

04/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

04/17/15

Short-Interest Reporting Deadline (Settlement Date of April 15, 2015) Financial Reporting Bi-Weekly FINOP

04/24/15

Quarterly FOCUS II/IIA Filing (Quarter End March 31, 2015) Financial Reporting Quarterly FINOP

04/24/15

Form Custody (Quarter End March 31, 2015) Financial Reporting Quarterly FINOP

04/24/15

Complete Monthly Financials and Net Capital Calculation (Period End March 31, 2015) Financial Reporting Monthly FINOP

04/29/15

Supplemental Statement of Income (SSOI) (Quarter End March 31, 2015) Financial Reporting Quarterly FINOP

04/29/15

Annual Audit Report (for FYE February 28, 2015) Financial Reporting Annually FINOP

04/29/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End March 31, 2015) Financial Reporting Monthly FINOP

04/30/15

Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader

04/30/15

MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal

04/30/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

05/01/15

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending March 31, 2015) Financial Reporting Quarterly FINOP

05/04/15

Short-Interest Reporting Deadline (Settlement Date of April 30, 2015) Financial Reporting Bi-Weekly FINOP

05/08/15

Customer Margin Balance Form Filing (Period End April 30, 2015) Financial Reporting Monthly FINOP

05/15/15 Month-end Compliance Review & Recap (month-end April 30, 2015) Supervision Monthly CCO/DSP

05/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

05/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

Page 7: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 7 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

05/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

05/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

05/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

05/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

05/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

05/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

05/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

05/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

05/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

05/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

05/19/15

Short-Interest Reporting Deadline (Settlement Date of May 15, 2015) Financial Reporting Bi-Weekly FINOP

05/22/15 Day before Memorial Day (3 p.m. early close) Market Holiday Annually

05/25/15 Memorial Day Market Holiday Annually

05/26/15

Monthly and Fifth FOCUS II/IIA Filings (Period End April 30, 2015) Financial Reporting Monthly FINOP

05/26/15

Complete Monthly Financials and Net Capital Calculation (Period End April 30, 2015) Financial Reporting Monthly FINOP

05/29/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End April 30, 2015) Financial Reporting Monthly FINOP

05/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

06/01/15

Annual Audit Report (for FYE March 31, 2015) Financial Reporting Annually FINOP

06/02/15

Short-Interest Reporting Deadline (Settlement Date of May 29, 2015) Financial Reporting Bi-Weekly FINOP

06/08/15

Customer Margin Balance Form Filing (Period End May 29, 2015) Financial Reporting Monthly FINOP

06/15/15 Month-end Compliance Review & Recap (month-end May 31, 2015) Supervision Monthly CCO/DSP

06/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

06/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

06/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

06/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

Page 8: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 8 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

06/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

06/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

06/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

06/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

06/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

06/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

06/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

06/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

06/17/15

Short-Interest Reporting Deadline (Settlement Date of June 15, 2015) Financial Reporting Bi-Weekly FINOP

06/23/15

Monthly and Fifth FOCUS II/IIA Filing (Period End May 31, 2015) Financial Reporting Monthly FINOP

06/23/15

Complete Monthly Financials and Net Capital Calculation (Period End May 31, 2015) Financial Reporting Monthly FINOP

06/26/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End May 31, 2015) Financial Reporting Monthly FINOP

06/29/15

Annual Audit Report (for FYE April 30, 2015) Financial Reporting Annually FINOP

06/30/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

07/01/15

Effective Date of FINRA Rule 3110(e) (Responsibility of Member to Investigate Applicants for Registration) Personnel As Needed CCO

07/01/15

FINRA Rule 4311(h)(2) Notification (Clearing Report Availability) Trading Annually CCO

07/02/15

Short-Interest Reporting Deadline (Settlement Date of June 30, 2015) Financial Reporting Bi-Weekly FINOP

07/02/15 Day before Independence Day (1 p.m. early close) Market Holiday Annually

07/03/15 Independence Day (observed) Market Holiday Annually

07/07/15

Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal

07/09/15

Customer Margin Balance Form Filing (Period End June 30, 2015) Financial Reporting Monthly FINOP

07/15/15

Quarterly Reporting of Customer Complaints (Quarter Ending June 30, 2015) Regulatory Reporting Quarterly CCO

07/15/15 Month-end Compliance Review & Recap (month-end June 30, 2015) Supervision Monthly CCO/DSP

07/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

Page 9: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 9 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

07/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

07/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

07/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

07/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

07/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

07/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

07/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

07/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

07/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

07/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

07/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

07/17/15

Short-Interest Reporting Deadline (Settlement Date of July 15, 2015) Financial Reporting Bi-Weekly FINOP

07/24/15

Form Custody (Quarter End June 30, 2015) Financial Reporting Quarterly FINOP

07/24/15

Quarterly FOCUS II/IIA Filing (Quarter End June 30, 2015) Financial Reporting Quarterly FINOP

07/24/15

Complete Monthly Financials and Net Capital Calculation (Period End June 30, 2015) Financial Reporting Monthly FINOP

07/29/15

Supplemental Statement of Income (SSOI) (Quarter End June 30, 2015) Financial Reporting Quarterly FINOP

07/29/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End June 30, 2015) Financial Reporting Monthly FINOP

07/30/15

Annual Audit Report (for FYE May 31, 2015) Financial Reporting Annually FINOP

07/30/15

SIPC-6 General Assessment Filing and Payment (for firms with December 31st FYE) Financial Reporting Bi-Annually FINOP

07/31/15

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending June 30, 2015) Financial Reporting Quarterly FINOP

07/31/15

Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader

07/31/15

MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal

07/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

08/04/15

Short-Interest Reporting Deadline (Settlement Date of July 31, 2015) Financial Reporting Bi-Weekly FINOP

Page 10: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 10 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

08/10/15

Customer Margin Balance Form Filing (Period End July 31, 2015) Financial Reporting Monthly FINOP

08/15/15 Month-end Compliance Review & Recap (month-end July 31, 2015) Supervision Monthly CCO/DSP

08/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

08/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

08/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

08/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

08/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

08/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

08/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

08/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

08/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

08/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

08/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

08/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

08/18/15

Short-Interest Reporting Deadline (Settlement Date of August 14, 2015) Financial Reporting Bi-Weekly FINOP

08/25/15

Monthly and Fifth FOCUS II/IIA Filing (Period End July 31, 2015) Financial Reporting Monthly FINOP

08/25/15

Complete Monthly Financials and Net Capital Calculation (Period End July 31, 2015) Financial Reporting Monthly FINOP

08/28/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End July 31, 2015) Financial Reporting Monthly FINOP

08/31/15

Annual Audit Report (for FYE June 30, 2015) Financial Reporting Annually FINOP

08/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

09/02/15

Short-Interest Reporting Deadline (Settlement Date of August 29, 2015) Financial Reporting Bi-Weekly FINOP

09/04/15 Friday before Labor Day (3 p.m. early close) Market Holiday Annually

09/07/15 Labor Day Market Holiday Annually

09/09/15

Customer Margin Balance Form Filing (Period End August 31, 2015) Financial Reporting Monthly FINOP

09/15/15 Month-end Compliance Review & Recap (month-end August 31, 2015) Supervision Monthly CCO/DSP

Page 11: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 11 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

09/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

09/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

09/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

09/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

09/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

09/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

09/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

09/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

09/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

09/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

09/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

09/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

09/17/15

Short-Interest Reporting Deadline (Settlement Date of September 15, 2015) Financial Reporting Bi-Weekly FINOP

09/24/15

Monthly and Fifth FOCUS II/IIA Filing (Period End August 31, 2015) Financial Reporting Monthly FINOP

09/24/15

Complete Monthly Financials and Net Capital Calculation (Period End August 31, 2015) Financial Reporting Monthly FINOP

09/29/15

Annual Audit Report (for FYE July 31, 2015) Financial Reporting Annually FINOP

09/29/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End August 31, 2015) Financial Reporting Monthly FINOP

09/30/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

10/01/15

Review of all registered persons and branch offices for proper reporting through Web CRD® in preparation for 2016 Renewals Renewals Annually FINOP

10/02/15

Short-Interest Reporting Deadline (Settlement Date of September 30, 2015) Financial Reporting Bi-Weekly FINOP

10/07/15

Alternative Periodic Reporting for Transactions in Muni Fund Securities (MSRB Rule G-15) Munis. Quarterly Muni Principal

10/08/15

Customer Margin Balance Form Filing (Period End September 30, 2015) Financial Reporting Monthly FINOP

10/12/15 Columbus Day Federal Holiday Annually

10/15/15

Quarterly Reporting of Customer Complaints (Quarter Ending September 30, 2015) Regulatory Reporting Quarterly CCO

Page 12: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 12 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

10/15/15 Month-end Compliance Review & Recap (month-end September 30, 2015) Supervision Monthly CCO/DSP

10/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

10/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

10/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

10/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

10/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

10/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

10/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

10/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

10/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

10/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

10/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

10/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

10/19/15

Short-Interest Reporting Deadline (Settlement Date of October 15, 2015) Financial Reporting Bi-Weekly FINOP

10/23/15

Quarterly FOCUS II/IIA Filings (Quarter End September 30, 2015) Financial Reporting Quarterly FINOP

10/23/15

Form Custody (Quarter End September 30, 2015) Financial Reporting Quarterly FINOP

10/26/15

Firms may begin to submit post-dated Forms U5 and BR Closing/Withdrawal (must be dated 12/31/14) as part of 2016 Renewals Renewals Annually FINOP

10/28/15

Complete Monthly Financials and Net Capital Calculation (Period End September 30, 2015) Financial Reporting Monthly FINOP

10/28/15

Supplemental Statement of Income (SSOI) (Quarter End September 30, 2015) Financial Reporting Quarterly FINOP

10/28/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End September 30, 2015) Financial Reporting Monthly FINOP

10/30/15

Annual Audit Report (for FYE August 31, 2015) Financial Reporting Annually FINOP

10/30/15

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending September 30, 2015) Financial Reporting Quarterly FINOP

Page 13: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 13 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

10/31/15

MSRB Rule A-14 (Annual Fee) Munis. Annually Muni Principal

10/31/15

Quarterly Disclosure of Order Routing Trading Quarterly CCO/Head Trader

10/31/15

MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal

10/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

11/01/15

Firms may begin to submit post-dated Forms BDW and ADV-W (must be dated 12/31/14) as part of 2016 Renewals Renewals Annually FINOP

11/03/15

Short-Interest Reporting Deadline (Settlement Date of October 30, 2015) Financial Reporting Bi-Weekly FINOP

11/09/15

Customer Margin Balance Form Filing (Period End October 30, 2015) Financial Reporting Monthly FINOP

11/09/15

Preliminary 2016 Renewal Statements and reports are available for viewing and printing Renewals Annually FINOP

11/11/15 Veterans Day Federal Holiday Annually

11/15/15 Month-end Compliance Review & Recap (month-end October 31, 2015) Supervision Monthly CCO/DSP

11/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

11/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

11/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

11/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

11/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

11/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

11/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

11/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

11/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

11/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

11/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

11/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

11/17/15

Short-Interest Reporting Deadline (Settlement Date of November 13, 2015) Financial Reporting Bi-Weekly FINOP

11/25/15

Monthly and Fifth FOCUS II/IIA Filing (Period End October 31, 2015) Financial Reporting Monthly FINOP

Page 14: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 14 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

11/25/15

Complete Monthly Financials and Net Capital Calculation (Period End October 31, 2015) Financial Reporting Monthly FINOP

11/25/15 Day before Thanksgiving Day(3 p.m. early close) Market Holiday Annually

11/26/15 Thanksgiving Day Market Holiday Annually

11/27/15 Day after Thanksgiving Day (1 p.m. early close) Market Holiday Annually

11/30/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

11/30/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End October 31, 2015) Financial Reporting Monthly FINOP

11/30/15

Annual Audit Report (for FYE September 30, 2015) Financial Reporting Annually FINOP

12/02/15

Short-Interest Reporting Deadline (Settlement Date of November 30, 2015) Financial Reporting Bi-Weekly FINOP

12/08/15

Customer Margin Balance Form Filing (Period End November 30, 2015) Financial Reporting Monthly FINOP

12/11/15

Deadline for receipt of 2016 Preliminary Renewal Statement payments Renewals Annually FINOP

12/14/15

Automatic Transfers for 2016 Preliminary Renewal Statements Renewals Annually FINOP

12/15/15 Month-end Compliance Review & Recap (month-end November 30, 2015) Supervision Monthly CCO/DSP

12/15/15 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

12/15/15 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

12/15/15 Sample Review of Transactions Trading Monthly CCO/DSP

12/15/15 Sample Review of New Rep files Personnel Monthly CCO/DSP

12/15/15 Review of Customer Complaints Internal Controls Monthly CCO/DSP

12/15/15 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

12/15/15 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

12/15/15 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

12/15/15 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

12/15/15 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

12/15/15 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

12/15/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

12/17/15

Short-Interest Reporting Deadline (Settlement Date of December 15, 2015) Financial Reporting Bi-Weekly FINOP

Page 15: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 15 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

12/23/15

Monthly and Fifth FOCUS II/IIA Filing (Period End November 30, 2015) Financial Reporting Monthly FINOP

12/23/15

Complete Monthly Financials and Net Capital Calculation (Period End November 30, 2015) Financial Reporting Monthly FINOP

12/24/15 Day before Christmas (1 p.m. early close) Market Holiday Annually

12/25/15 Christmas Day Market Holiday Annually

12/26/15

Last Day to submit 2016 Preliminary Renewal Filing and Payment prior to year-end Renewals Annually FINOP

12/29/15

Web CRD/IARD are unavailable due to 2016 Final Renewal Statement and renewals processing Renewals Annually FINOP

12/29/15

Supplemental Inventory Schedule (SIS) Filing (Quarter End November 30, 2015) Financial Reporting Monthly FINOP

12/30/15

Annual Audit Report (for FYE October 31, 2015) Financial Reporting Annually FINOP

12/30/15

Web CRD/IARD are available for QUERY-only and the creation of "Pending" 2016 Renewal filings Renewals Annually FINOP

12/31/15

FinCEN 314(a) Notification Review & Self-Verification AML Bi-Monthly AMLCO

12/31/15

Mailing of Annual Disclosure Documents to Clients (Privacy Policy; BCP; AML, etc.) Communications Annually CCO

12/31/15 Year-end Compliance Review & Recap (2015) Supervision Annually CCO/DSP

12/31/15 Year-End Compliance Review Checklist Supervision Annually CCO/DSP

12/31/15 Year-End Review/Update of Written Supervisory Procedures- Review and Approval by CCO Internal Controls Annually CCO/DSP

12/31/15 Year-End Review/Update of Continuing Education Program (CEP)- Review and Approval by CCO Education & Training Annually CCO/DSP

12/31/15 Year-End Review/Update of Business Continuity Plan (BCP)- Review and Approval by CCO Internal Controls Annually CCO/DSP

12/31/15 Year-End Review/Update of Supervisory Control System (WSCS)- Review and Approval by CCO Internal Controls Annually CCO/DSP

12/31/15 Year-End Review/Update of AML Program- Review and Approval by AMLCO AML Annually AMLCO

12/31/15 Year-End Review/Update of Cybersecurity Procedures- Review and Approval by CCO Cybersecurity Annually CCO/CIO

12/31/15 Year-End Review/Update of Privacy Policy- Review and Approval by CCO Internal Controls Annually CCO/DSP

12/31/15 Year-End Review of Vendors & Service Providers (Contracts & Service Level) Due Diligence Annually CCO/DSP

Page 16: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 16 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

12/31/15 Year-End Review of Associated Persons List (Including Recently Hired/Terminated Rep Lists) Personnel Annually CCO/DSP

12/31/15 Annual Review of FINRA Membership Agreement and Form BD Regulatory Reporting Annually CCO/DSP

12/31/15 Year-End Review and Update of Form BR Filings (Branch Offices) Branch Supervision Annually CCO/DSP

12/31/15 Year-End Review and Update of Expense Sharing Agreement (if applicable) Financial Reporting Annually FINOP

01/05/16

Short-Interest Reporting Deadline (Settlement Date of December 31, 2015) Financial Reporting Bi-Weekly FINOP

01/11/16

Customer Margin Balance Form Filing (Period End December 31, 2015) Financial Reporting Monthly FINOP

01/15/16

Quarterly Reporting of Customer Complaints (Quarter Ending December 31, 2015) Regulatory Reporting Quarterly CCO

01/15/16 Month-end Compliance Review & Recap (month-end December31, 2015) Supervision Monthly CCO/DSP

01/15/16 Sample Review of New Customer Accounts Customer Accounts Monthly CCO/DSP

01/15/16 Review & Confirm OFAC Check/CIP Verification on New Client Accounts AML Monthly CCO/DSP

01/15/16 Sample Review of Transactions Trading Monthly CCO/DSP

01/15/16 Sample Review of New Rep files Personnel Monthly CCO/DSP

01/15/16 Review of Customer Complaints Internal Controls Monthly CCO/DSP

01/15/16 Sample Review of Activity/Exception Reports Trading Monthly CCO/DSP

01/15/16 Sample Review of Correspondence, Retail/Institutional Communications (written/electronic) Communications Monthly CCO/DSP

01/15/16 Sample Review of Rep Outside Brokerage Account Statements Internal Controls Monthly CCO/DSP

01/15/16 Sample Review of Rep Outside Business Activities Internal Controls Monthly CCO/DSP

01/15/16 Review of Social Media Use by Associated Persons Communications Monthly CCO/DSP

01/15/16 Review and Update Restricted Securities & Watch List Internal Controls Monthly CCO/DSP

01/27/16

Annual Schedule I Filing (for FYE December 31, 2015) Financial Reporting Annually FINOP

01/27/16

Quarterly FOCUS II/IIA Filing (Quarter End December 31, 2015) Financial Reporting Quarterly FINOP

01/27/16

Form Custody (Quarter End December 31, 2015) Financial Reporting Quarterly FINOP

01/27/16

Complete Monthly Financials and Net Capital Calculation (Period End December 31, 2015) Financial Reporting Monthly FINOP

01/29/16

Annual Audit Report (for FYE November 30, 2015) Financial Reporting Annually FINOP

Page 17: 2015 Broker/Dealer Compliance Calendar

2015 Broker/Dealer Compliance Calendar

Prepared by Financial Registrations, Inc. Page 17 of 17 2015 Broker/Dealer Compliance Calendar BDCC Ver.01312015

Due Date Completed Compliance Task Category Frequency Assignment Notes/Comments

01/31/16

MSRB Rule G-37 Reporting Requirement Munis. Quarterly Muni Principal

02/01/16

Supplemental Statement of Income (SSOI) (Quarter End December 31, 2015) Financial Reporting Quarterly FINOP

02/01/16

SIPC-7 General Assessment Reconciliation Filing and Payment (for firms with December FYE) Financial Reporting Bi-Annually FINOP

02/01/16

Supplemental Inventory Schedule (SIS) Filing (Quarter End December 31, 2015) Financial Reporting Monthly FINOP

02/03/16

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (OBS) (Quarter Ending December 31, 2015) Financial Reporting Quarterly FINOP

02/29/16

Annual Audit Report (for FYE December 31, 2015) Financial Reporting Annually FINOP

Financial Registrations, Inc. is a compliance management consulting firm providing registration and compliance advisory services to FINRA member broker/dealers and SEC and State registered investment advisers. For more information on this topic or other compliance related matters, please contact: Brian K. Miller Vice President, Business Development [email protected]

Financial Registrations, Inc. 25602 Alicia Parkway #107 Laguna Hills, CA 92653 www.financialregistrations.com

Toll-free (800) 641-1818 Direct (949) 770-6154 Fax (949) 770-6198