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FINRA Branch Exam Questionnaire

March 15, 2011
When FINRA notifies a broker-dealer that it plans to examine one of its branch offices, FINRA will ask for certain information and documents that must be submitted electronically in advance of the scheduled visit.  Let's take a look at one such checklist that a firm recently received. 
[C-I Note:  We welcome anonymous correspondence that firms receive from regulators - if you submit, we'll share it with our readers.]
__________________________________________
  
Dear Member Firm:

In order to expedite our examination, please provide as much of the following information, in electronic format, as possible.  Please label each document transmission with the corresponding request number.

Please indicate, in writing, if any of the requested items are not applicable.  Provide a memorandum identifying each request number that is not applicable.

1)   Please provide the org chart for the branch.  For any individuals with supervisory responsibility, please provide a list of their appropriate registration as well as a description of their supervisory duties.

2)   Please provide a list of associated persons of the branch, their registration, crd number, any internal identification number used by the firm, and the person designated to supervise each person.

3)   Please provide a list of all producing managers of the branch and the individual designated to supervise that individual.

4)   Please provide trade blotter for the period, ________ through ________, and the corresponding evidence that those trades are being reviewed in accordance with the branch’s procedures.  Please ensure the blotter contains trade date, price, quantity, commission, security description, and registered person name.

5)   Please provide all order tickets for trades occurring on Monday _____________.

6)   Please provide the firm’s procedures addressing order errors.   Please provide a list of order errors for the months of ________, __________ and ___________ 2011.

7)   Please provide a list of all account name or designation change for the months of ________, __________ and ___________ 2011.  Please note any instances where those designation changes are for trades done by producing managers.

8)   Please provide a blotter (preferably in excel) that contains all customer transmittal of funds or securities for the period of ________, __________ and ___________.  Please include all instances of customer hand delivery if checks to RR’s.

9)   Please provide the branch’s record that evidences compliance with SEC rule 17a-3(a)(21).

10)   Please provide the firm’s/branch’s procedures for granting Reg. T or 15c3-3 extensions to customers. Please provide a list of all Reg. T and 15c3-3 extensions for the period of ________, __________ and ___________. Please ensure the list includes the customer name and representative name.

11)   Please provide a list of all accounts that are currently subject to a Reg. T freeze or was subject to a Reg. T freeze during the months of ________, __________ and ___________. Please ensure that this list includes the RR name.

12)   Please provide a list of all customers who use P.O Box. Please ensure the list includes customer name, account number, full P.O box address, and RR name.

13)   Please provide a list of customer change of address for the months of ________, __________ and ___________. Please ensure the list contains customer name, account number, old address, new address, date of change, and RR name. Please also provide the firm’s procedures governing such changes.

14)   For the first ten customer change of address from the sample in item # 13 above, please provide evidence that the firm confirmed the changed with the customer to both the old address and the new address.

15)   Please provide a list of all customer investment objective change for the months of ________, __________ and ___________. Please ensure the list contains the customer name, customer account, old objective, new objective, date of change, and RR name. Please also provide the firm’s procedures governing such changes.

16)   For the first ten items listed in request # 15 above, please provide evidence that the firm confirmed the change with the customer.

17)   Please have the individuals listed on the attached spreadsheet and all of the branch office’s principals/supervisors complete the personal activity questionnaire.

18)   Please provide a list of all branch employees with brokerage accounts and the name of the brokerage (do not include accounts in which the RR or principal cannot direct trades, such as 401k accounts, mutual funds etc). If the branch’s top ten revenue generating producers have brokerage accounts, please provide their ________, __________ and ___________ account statements. Please also provide this for the branch’s registered principals.

19)  Please provide a list of all e-mail and instant messaging addresses used by associated persons of the branch. Please provide the firm’s hard copy correspondence file for the months of ________, __________ and ___________.

20)  Please provide evidence that the branch office is in compliance with the Firm’s policies and procedures regarding the review of electronic correspondence for the period of ________, __________ and ___________.

21)  Please provide all e-mail and instant messages for the period of _______ through ________for the following RRs: 

22)  Please provide access to onsite, the customer complaint file for the period of ______ through the present.  Please also provide the arbitration and litigation file for this same time period.

23)  Please provide the two most recent branch inspection reports. Please ensure the reports name the individual responsible for conducting the inspection.

24)  Please provide a listing of employees that have conducted seminars during the previous 12 months.  Please include the employees name and the title of the seminar. 

25)  Please provide a listing of employees who engage in outside business activities.  Please include the employees name and a description of the activity(s).