"Associated persons" who are involved directly or indirectly in any aspect of 16 "covered" functions must register as operations professionals.  FINRA EVP and General Counsel Marc Menchel told attendees at the SIFMA Ops 2011 Conference that this would include non-clerical persons who are involved in one fashion or another of those specific back office functions. 

Of course, Mr. Menchel was referring to a proposed rule that FINRA filed with the SEC in mid- March - which covers training, examination and registration procedures.  The rule was drafted to counter concerns that emanated from the Bernie Madoff Ponzi scheme.  FINRA contends that back office personnel at Bernie Madoff''s securities firm had shown no recognition of its regulatory responsibilities.

The 16 covered functions include:

If engaged in any of those 16 functions, then a non-clerical person is likely to be an "associated person."  That's a broad interpretation of who's likely to be covered.  SEC licensing efforts had been directed at senior managers with responsibility for such functions, supervisors or individuals who approve or authorize work in the covered functions and persons who can commit capital toward the execution of any of the covered functions.   [Securities Tech'gy Monitor, 5/2/11]