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COMMENT LETTERS - REGULATORY COMPLIANCE INFORMATION

2015 Small Firm Compliance, November Reminders & Information

REMINDERS & INFORMATION
 
Here are a few noteworthy items this week:
 
ACTION ITEM:  FINRA REG NOTICE 15-40: BROKER-DEALER, INVESTMENT ADVISOR FIRM, AGENT, and INVESTMENT ADVISOR REPRESENTATIVE, and BRANCH RENEWALS FOR 2016
The 2016 Renewal Program begins on November 16, 2015, when online Preliminary Statements are available to all firms on Web CRD/IARD. Full payment of Preliminary Statements is due by December 18, 2015.

This is the annual renewal process for both individual and firm registrations. Be sure to log on to your CRD/IARD account to view your Prelim Statement, verify that all of the information is correct (personnel and offices), make any changes necessary, and then be sure you have enough funds deposited in your CRD/IARD account by December 18th to pay for your renewals. Put a reminder on your calendar to log into CRD/IARD on January 4, 2016 to review your Final Statement. If the Final Statement is different than the Prelim, be sure you deposit funds in your account by January 15, 2016. 
 
ACTION ITEM:  FINRA SMALL FIRM ELECTIONS: BALLOTS DUE NOVEMBER 13th
As a reminder, the voting period for the FINRA Small Firm Advisory Board and District Committee elections ends on November 13, 2015.

Be sure your voice is heard and place your vote - it really does matter. I know a lot of you think this is a waste of your time, but I assure you it is not. Do we, as small firm members, enjoy a dominant voice with the regulators or in the rule making process? No, the truth is we do not, but what I can tell you from experience is that if small firms are not represented well (and passionately) on these boards and committees then we will most assuredly be even more handicapped than we are at present. To effect change (or even have the CHANCE to effect change) you have to be sitting at the table where the conversation is taking place, so be sure you elect the right people to sit at these tables to represent your firm and our sector. 
 
FOR ASSET MANAGEMENT FIRMS
SIFMA and Broadridge release Operational Risk white paper for Asset Managers
SIFMA and Broadridge have joined forces to provide insight on how to develop an effective Operational Risk Management (ORM) program. These insights were recently released in a white paper titled, "Operational Risk: Tailoring the right model for asset management firms." Download the white paper to learn more about the key considerations for your firm, including Strategy, Vendor Management, Challenges, and more.  http://www.sifma.org/issues/item.aspx?id=8589956868
 
DOL FIDUCIARY RULE PROPOSAL - ONGOING WORK
Take Action to Keep Retirement Open
The Department of Labor has proposed a retirement regulation that will harm middle-class families preparing for retirement - the very people it intends to protect - with fewer choices, limited access to advice, and higher costs. Visit www.keepretirementopen.com to learn more about this regulation and contact your Members of Congress with your concerns today.

Morningstar Report on DOL Fiduciary Proposal
Morningstar recently published a report on the unintended (and, arguably, the intended) consequences of the DOL proposal. The report estimates that the actual cost of the proposal would $2.4b to implement instead of the $1.1b DOL estimated, and argues that the rule effectively bans commissions and equates it to the UK Retail Distribution Review. The full report is attached for your review.

Bipartisan House Members Outline Legislative Principles to Ensure Retirement Advisors Protect Clients' Best Interests
Republican and Democratic lawmakers this week outlined a series of legislative principles that will help strengthen the retirement security of working families and ensure retirement advisors protect their clients' best interests. The congressional effort is taking place as bipartisan concerns grow over a regulatory proposal by the Department of Labor that many individuals fear will make it harder for low- and middle-income families to plan for retirement.
 
*** I will be speaking on a panel next week at the FINRA Small Firm Conference in California. If you are attending, I look forward to meeting you in person.
 
All the best,
PAIGE W. PIERCE
 

Paige Pierce