Insights

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Comment Letter - Lessons from the Covid-19 Pandemic - Regulatory Notice 20-42

Integrated Investment Solutions, 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, 2019 through September 30, 2020. Our audit was conducted by a well-known internationally acclaimed accounting firm which reviewed and tested the control environment for the services we provide and issued a report which deemed that our control objectives were suitably designed and operated effectively.

We pride ourselves with our professional staff, their integrity, and work ethics. They are highly trained individuals so...

Mr. Stupay will be speaking on “Advanced Net Capital Issues” at the teleconference, where he will bring his expertise in Broker-Dealer related accounting and FINOP related issues to the forum. Mr. Stupay is currently a Senior Managing Director at Integrated Solutions and is registered as a Financial and Operations Principal with several Broker-Dealers. Additionally, he acts in a consultant capacity on Broker-Dealer compliance related issues, which allows him to offer advice and guidance from varying perspectives within the regulatory environment. He will be joined by an equally distinguished list of fellow panelists who will cover other issues including PCAOB Updates and Common...

Michael Stupay, Senior Managing Director of Integrated Solutions is participating as a Roundtable Panelist at Citrin Cooperman’s upcoming “Virtual Roundtable” on November 12, 2020.

Bringing his extensive industry experience and insight to the panel, Mr. Stupay will participate in FINOP related discussions on a myriad of topics. He will offer his advice and guidance from an accounting and compliance perspective on subjects relevant to the impact of COVID-19 on the industry and the challenge it brings to a Broker-Dealer’s internal controls. Related topics such as SEC and FINRA guidance on membership agreements, as well as PPP loan forgiveness treatment will also be addre...

We love regulation! We owe our success to the regulatory environment in the financial services industry. From a selfish standpoint, we can say that we enjoy regulations. Similar to the way doctors love the flu and dentists love cavities, we are happy that we have a raison d'être.

Now that I have been associated directly or indirectly with the financial services industry for over five decades, I have come to the realization that while I value regulation, I really hate some of the regulations. I don’t hate all regulation since I recognize that at least some regulation is necessary. On the other hand, I recognize that the current regulatory environment in the securities industry is s...

By Peggy E. Chait

40 years ago, when I started working in this illustrious industry, we call Wall Street, much of what was agreed upon was done with a handshake. A person’s word was his or her word, and “just and equitable principles of trade” as espoused in FINRA Rule 2010, were understood and confirmed through the extension of a hand. Trust existed between client and professional and the number of rules that existed to “guide” the behavior of the professional was limited. Trust existed between professionals as well. For some reason, written agreements between Broker-Dealers were concise, and made their point without pages and pages of representations and warran...

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Regulatory Notice 20-04 Capital Acquisition Brokers

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Regulatory Notice 20-05 Continuing Education Program Transformation

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&...