On November 4, 2022, the amended Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) goes into effect. The new Marketing Rule amends and merges two previous rules, the “advertising rule” (the former Rule 206(4)-1) and the “solicitation rule” (the former Rule 206(4)-3), into one overarching rule that regulates the marketing of investment advisers. In addition, Rule 204(2) “Books and Records” as well as Form ADV have been amended to address the changes. This memorandum will specifically address the impact of the New Marketing Rule on broker dealers marketing investments to potential investor...
Nov
07
Aug
19
Please follow the link below to download our comment letter.
Jul
14
Apr
25
Rafael Beck, a Senior Managing Director of Integrated Solutions and member of the Stock Brokerage Committee of the New York State Society of CPAs (NYSSCPAs), will be speaking at an upcoming Auditor-FINOP panel hosted by the NYSSCPAs at their Broker-Dealer Conference to be held on May 4, 2022.
The panel discussions will include lessons from the most recent audit filing season. Topics to be covered are the 60 vs. 90 day filing deadline extension, staffing and scheduling challenges, accounting, reporting and regulatory changes, Footnote 74 and Exemption Reports, Pass Through Entity Tax treatment, inspections and other relevant issues. Additionally, the session will include a retrospective review...
Apr
25
By Peggy E. Chait
We have all learned the concept of assigning blame since we were children. Who among us did not chant at the top of our voices in unison, “Who stole the cookie from the cookie jar? Who me? Yes you. Couldn’t be. Then who?” Pointing our finger and the act of CYA (cover your a…) go hand in hand in our litigious society and Regulators encourage us to assign responsibility in order to make their jobs more lucrative and easier. Yes, I know about whistleblowers and the need to protect them for the betterment of society, and I am in agreement about the dangers of retaliation given their whistleblowing revelations. No contest there. What I would like to exami...
Dec
28
For the fourth consecutive year, Integrated Investment Solutions (IIS), an independent alternative investment fund administrator announces the successful completion and issuance of its Accounting, Administration and Investor Services System and Organizational Controls (SOC) 1 Type 2 Report for the period October 1, 2020, through September 30, 2021. Our audit was once again conducted by a well-known internationally acclaimed accounting firm, which issued a report indicating its review and evaluation of the control environment for the services we provide. The report deemed that our control objectives were suitably designed and operated effectively.
We at Integrated Investment Solutions, a busin...
Nov
22
By Peggy E. Chait and Howard Spindel
For those of you that are old enough to remember the slogan, “when EF Hutton talks, people listen”, and the powerful effect the ad had on the general public, we can now attest that when the Wall Street community gathers in unity and speaks out, the regulators eventually listen.
We at Integrated Solutions are proud to be a member of the community that has been speaking up for a soon to be effective change in FINRA’s rule 1210. See FINRA Regulatory Notice 21-41. As a leading provider of financial accounting and compliance services to the financial services industry, we have written comment letters to FINRA on several occasions (June 30, 2020...
Oct
29
Michael Stupay, Senior Managing Director of Integrated Solutions will be a keynote speaker at the New York State Society of CPAs’ “Stock Brokerage Committee CPE Session” which will be held on December 2, 2021. The afternoon Tech Session webinar will specifically address, “Broker-Dealer-Hot Topics and Practical Considerations.”
Mr. Stupay brings decades of experience to the forum. He has been a Senior Managing Director of Integrated Solutions since 1994, which services a myriad of regulated Broker-Dealers and Registered Investment Advisors. He is also involved in Integrated Investment Solutions LLC, the Fund Administration arm of Integrated Solutions. He has been ...
Jun
03
By Peggy E. Chait
Piaget’s theory of “object permanence” recognized that a developmental milestone in an infant’s life is when they cognitively understand that an object still exists, even if the infant cannot see or perceive it. So too, exists the ability of a Broker/Dealer to function efficiently and effectively without anyone conducting an onsite Branch Office Inspection. It has never before been so well evidenced that the need for an onsite examination is a fossil of previous generations, and that the Covid-19 pandemic worked like a team of well-trained archeologists to uncover this. For FINRA requested information and documentation from remote locations, including...
May
25
By Peggy E. Chait
2020 is a year that most of us would like to forget for a myriad of reasons, the foremost being the COVID-19 pandemic. It has wreaked havoc on our nation, our citizens, livelihoods, and the faith we have in each other and our country. It has had far reaching implications in our Wall Street community. Many issues that affect the way we conduct our business have been addressed by the regulatory community. Here are a few that we had touched upon in our Comment Letter which was submitted to FINRA on February 16, 2021.
> Broker/Dealers can function effectively even when their employees are not physically located under one roof, in one state or perhaps one country. Connectivity ...
