This AWC underscores the importance of having strong procedures in place to safeguard against the inadvertent loss of required books and records. Still, accidents happen and sometimes required records are lost. If this happens, consider whether to self-report the fact of the loss to FINRA. Also, consider whether the firm has a reporting obligation under SEA Rule 17a-11(c), which requires every broker or dealer that "fails to make and keep current the books and records required by Section 240…
The reminds NYSE Floor Brokers that NYSE Rule 36, as interpreted by , limits the provision by floor brokers of "market looks" to third parties. For this purpose, the term "market look" means "information about buying and selling interest in the market." Specifically, as stated in NYSE Information Memo 14-2, market looks may only be provided to persons who are customers "provided that the customer is a person whom the Floor broker reasonably believes is receiving the order-related message in…
The identifies a number of concerns with respect to non-US individuals that refer business to a US firm. The most obvious is that a US firm cannot pay individuals that are not properly regulated and licensed associated persons. A point that may be less obvious, but more significant, is that FINRA criticized the US broker-dealer for allowing the unregistered individuals access to the firm's trading platform for the purpose of placing trades on behalf of the referred customers.
As reflected in the AWC, FINRA's rules relating to bond prices and mark-ups/mark-downs in customer transactions are complicated, with the results being that firms continue to fall short of what the rules require and what FINRA wants to see.
With respect to pricing, as laid out in the AWC, FINRA requires that the customer be given a "fair" price. Supplementary Material .02 to FNRA Rule 2121 requires this fair price be based upon the "prevailing market price." In the first…
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This AWC underscores the importance of having strong procedures in place to safeguard against the inadvertent loss of required books and records. Still, accidents happen and sometimes required records are lost. If this happens, consider whether to self-report the fact of the loss to FINRA. Also, consider whether the firm has a reporting obligation under SEA Rule 17a-11(c), which requires every broker or dealer that "fails to make and keep current the books and records required by Section 240…
The reminds NYSE Floor Brokers that NYSE Rule 36, as interpreted by , limits the provision by floor brokers of "market looks" to third parties. For this purpose, the term "market look" means "information about buying and selling interest in the market." Specifically, as stated in NYSE Information Memo 14-2, market looks may only be provided to persons who are customers "provided that the customer is a person whom the Floor broker reasonably believes is receiving the order-related message in…
The identifies a number of concerns with respect to non-US individuals that refer business to a US firm. The most obvious is that a US firm cannot pay individuals that are not properly regulated and licensed associated persons. A point that may be less obvious, but more significant, is that FINRA criticized the US broker-dealer for allowing the unregistered individuals access to the firm's trading platform for the purpose of placing trades on behalf of the referred customers.
Of…
As reflected in the AWC, FINRA's rules relating to bond prices and mark-ups/mark-downs in customer transactions are complicated, with the results being that firms continue to fall short of what the rules require and what FINRA wants to see.
With respect to pricing, as laid out in the AWC, FINRA requires that the customer be given a "fair" price. Supplementary Material .02 to FNRA Rule 2121 requires this fair price be based upon the "prevailing market price." In the first…