Insights

In 2013, the SEC adopted amendments to the net capital rule that eliminated references to credit ratings that had previously applied to non-exotic debt securities such as high grade corporate debt and commercial paper that have a ready market.

Broker-dealers were supposed to either use a 15% haircut for their portfolios of these items or to have procedures in place to determine whether they have minimal credit risk. We can’t blame the SEC for changing the rules as they had little choice but to comply with the law. The changes were dictated by the politicians in Congress that passed the Dodd-Frank Act. That Act was a reaction or an over-reaction to abuses in the credit ratings industry. ...

Regulation Best Interest (or "Reg BI") is an SEC mandate that every broker/dealer and investment adviser should understand. Form CRS must be provided to all natural persons who are investors/customers of Broker/Dealers and Investment Advisers. The following link will provide you with additional information should you wish to explore it further: https://www.sec.gov/rules/final/2019/34-86031.pdf

As of June 30, 2020, all broker-dealers and investment advisers should have policies and procedures in place to comply with SEC Rule 15l-1 which covers "Regulation Best Interest" or “Reg. BI”. Unlike FINRA's "Suitability" rule (FINRA Rule 2111), which applies only to “retail investors&...

FINRA recognizes the current economic turbulence the spread of COVID-19 has caused small firms, in particular. With that in mind, FINRA is providing temporary relief for small firms with respect to 2020 Gross Income Statements and Personal Assessments (Annual Assessments).

Generally, payment of Annual Assessments is due in full within 30 days of receipt or in four quarterly installments. In 2020, FINRA is permitting small firms—identified under the FINRA By-Laws as having no more than 150 registered persons—to treat 2020 Annual Assessments as billed as of August 1, 2020, rather than as due upon receipt in April. Further, small firms that choose to do so will be allowed to pay 5...

Integrated Investment Solutions, an independent alternative investment fund administrator and a business unit of Integrated Solutions℠, is once again pleased to announce the successful completion of its Fund Accounting, Administration, and Investor Services System and Organization Controls (SOC) 1 Type 2 Report for the period October 1, 2018, to September 30, 2019.

Integrated Investment Solutions is comprised of highly trained professionals who are committed to complying with all regulations governing our industry and upholding the integrity of client information. Our professionalism and commitment to the standards of control in accordance with Statement on Standards for Attestation Engagemen...

Integrated Investment Solutions, an independent alternative investment fund administrator and a business unit of Integrated Solutions℠, today announced the successful completion of its Fund Accounting, Administration, and Investor Services System and Organization Controls (SOC) 1 Type 2 Report for the period January 1, 2018, to September 30, 2018.

Integrated Investment Solutions is comprised of highly trained professionals who are committed to complying with all regulations governing our industry and upholding the integrity of client information. Our professionalism and commitment to the standards of control in accordance with Statement on Standards for Attestation Engagements No. 18 issued b...

Integrated Solutions is sponsoring the Crypto Currency Forum to be held in New York on April 18, 2018. The Crypto Currency Forum was started to provide a venue where professionals who have an interest in Crypto Currencies and Block Chain technology can exchange ideas and find out the latest innovations in the rapidly evolving crypto world. We are proud to be part of this event. For additional information about this event please follow the link below.

https://cryptocurrencyfm.com/

Please follow the link below to download our comment letter.

Regulatory Notice 17-14 Capital Formation

Please follow the link below to download our comment letter.

Regulatory Notice 17-20

Recent developments that have become, or will likely become, hot buttons.

Rule 3210 – defining the undefinable – because so many of you have asked

Effective April 3, 2017, FINRA Rule 3210 became effective (replacing FINRA Rule 3050) and confusion reigned. The Rule:

• requires all associated persons of the broker dealer to obtain prior written consent of the firm when opening a brokerage account at another broker dealer or financial institution and;

• adds categories of persons subject to FINRA rule 3210 based on beneficial interest.

Rule 3210 specifies the types of accounts in which Associated Persons are perhaps rebuttably presumed to have a beneficial interest, those being:

• the spouse of...

On May 4, 2017, our Senior Managing Director, Mr. Michael Stupay, attended the NYSSCPA Broker/Dealer Conference held in New York as one of the panelists on the FinOps and Auditors session. The panelists shared their experiences in the third year of auditing under PCAOB standards. What is the PCAOB stressing in their inspections, how is that changing the auditor’s approach, and what issues does that create for FinOps, in preparing for the auditors?