Insights

Please follow the link below to download our comment letter.

Comment letter on Release No. 34-92183

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...

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 ...

Michael Stupay, a Senior Managing Director of Integrated Solutions and a long-standing 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 5, 2021.

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, accounting, reporting and regulatory changes, CECL implementation and effect, Footnote 74 and Exemption Reports, PPP Loans impact on net capital, FINOP on-site visits guidance, inspections and other relevant issues. Additionally, the...

By Peggy E. Chait

In my younger days, like many women, I was somewhat attracted to the “bad boy.” He was somewhat aloof, ran a bit wild and didn’t conform to the rules. Yet, he was what I wanted. Perhaps when he grew up, he would turn into a law-abiding, conservative Wall Street gentleman, and by then I knew better.

I also remember as the Chief Compliance Officer and Chief Financial Officer of a NYSE Member Firm, back in the mid 1980’s, reviewing U4 forms and disciplinary histories. I have to confess that I was sometimes amused by what I saw disclosed. People that you would least suspect were anything other than upstanding citizens their entire lives, had their past dal...

Please follow the link below to download our comment letter.

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...