FirstMark Regulatory Solutions is a broker-dealer compliance consulting firm that offers a wide range of services including the filing of a FINRA new member application or “NMA” as it is referred to in the industry. The NMA filing is a substantial undertaking and FirstMark often receives inquiries about what FINRA expects of applicants – specifically, …
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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 …
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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 …
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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 …
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FINRA Membership Application Insights
The FINRA Membership Application takes several forms, and frankly has received a fair amount of criticism over the years. The primary concerns that broker-dealers have voiced over the years are that the application process takes too long and is too complicated. FINRA has addressed these concerns in recent years by creating a centralized group based …