FINRA General Securities Principal Registration for NMAs

More studying? Are you kidding? Often this is the question that FirstMark Regulatory Solutions gets when discussing the FINRA general securities principal registration requirements with clients who have already taken the Series 7 and 63 exams. The question of who is required to have a FINRA general securities principal registration can get complicated.  In a …

The FINRA New Member Application – How Long Does it Take

Prospective consulting clients often ask the question, “How quickly can I get my FINRA New Member Application approved?” And unfortunately, the answer always seems to be the same, “Well that depends.” And it really does depend. Factors that Slow the FINRA New Member Application Process A FINRA New Member Application, or NMA, is subject to …

FINRA BD Startup Cost

“What is the FINRA BD Startup Cost?”  That is a question frequently fielded by FirstMark Regulatory Solutions, a broker-dealer consulting firm which helps individuals form new FINRA broker-dealers. And, when providing the answer to this question it is often complex and variable, depending on the nature and size of the planned business. So let’s walk …

Starting a Broker Dealer – Email Retention Requirement

If you a thinking about starting a broker dealer make sure you consider the email retention requirement early in the process to ensure time to set up archiving as required by SEC Rules. A common finding of examinations and inspections relates to the failure to maintain electronic communications. And when starting a broker dealer this is …

Why Does FINRA Lapse NMA and CMA Applications?

FINRA’s New Member Application (or “NMA”) process is often viewed as complex and time-consuming. And as a practical matter, that is generally the case. FINRA’s NMA rules as they currently exist were written with a presumption that the prospective broker-dealer must supply a complete and comprehensive application. The rules provide that FINRA may reject an …

The FINRA Membership Interview

One of the very important steps in FINRA’s new member application process (also referred to as the “NMA” process) is the FINRA membership interview. The FINRA membership interview is required by NASD Rule 1013(b)(1). A FINRA membership interview must occur with the prospective applicant prior to the issuance of a decision on any FINRA membership application. Rule 1013(b)(2) …

The FINRA Rebuttable Presumption of Denial

FINRA’s new member application process (also referred to as the “NMA” process) is a complex and time consuming process. The goal of the process is to obtain FINRA’s approval of a new broker-dealer. However, getting to that goal involves a significant commitment of time and resources. So before making this investment, it is important to …