Wednesday, November 9, 2011

Annual FINRA Entitlement User Accounts Certification

Attention Advisors!
You should have received an email today from FINRA for the 
Annual FINRA Entitlement User Accounts Certification

The purpose of this email is to ensure that each firm has accurate information for the IARD and CRD systems. The process is quick and simple (if you have your account access handy!)

The SAA ("Super Account Administrator") for your firm must log into your FINRA account at

Once you login, you will see this screen below. Click the link
Click here to begin User Accounts Certification Process.
Then follow the prompts. If your user information is correct, scroll to the certification (example below) and complete the form.

If you have trouble logging into your account or need to make changes to Administrators, give us a call at 617-800-0388 or email

Please email us at when you have completed this to help us ensure this does not slip through. You will receive a confirmation email that you can forward to us. THANKS!

Please note:  If user accounts are not certified within the 30-day certification period (Deadline: 12/9/11), the capability to your IARD/CRD account will be disabled. 

Here's the text of the FINRA Communication
Start Date: 11/09/2011
Due Date: 12/09/2011

One of the responsibilities of FINRA Super Account Administrators (SAA) is to ensure that users in their organization who require access to applications in the FINRA Entitlement Program to perform their job responsibilities are properly entitled to these applications and the sensitive data that these applications may contain. While FINRA encourages administrators to review user accounts periodically throughout the year, FINRA is launching an annual user accounts certification program to enhance this review process. The purpose of this email is to notify you that today begins FINRA's 2011 Entitlement User Accounts Certification Period. 

During this 30-day certification period, you will need to review your organization's user accounts to determine that:
  • each user has a continuing need to access FINRA application(s) on the organization's behalf;
  • each user is entitled only to the applications and privileges needed to perform current job responsibilities; and
  • only users who require access to sensitive data (e.g., Criminal History Record Information, social security or tax identification numbers, dates of birth) are entitled to access this type of data

For your convenience, you can download your user account information into a report to send to other individuals within your organization to confirm individual's appropriate entitlement, including access to applications, privileges, and sensitive data. FINRA recommends that you certify your users on the same day you request the download to prevent having to perform a subsequent review of your users as the entitlement data may have changed since the download was requested.

If user accounts are not certified within the 30-day certification period, the capability to create, edit and clone accounts within an organization will be disabled for all Administrators and will remain disabled until an organization completes the certification process. 

To begin the certification process, please click here

Additional entitlement information can be found on the FINRA Entitlement Program page.

If you have any questions concerning the certification process, please contact the Gateway Call Center at:
(301) 869-6699 (Broker/Dealers)
(240) 386-4848 (Investment Advisers) 

Thank you.

Tuesday, November 8, 2011

IARD System Changes

Effective on 11/7/11, FINRA released enhancements to the 

Investment Adviser Registration Depository ("IARD") system to prepare for SEC to State

transitions for mid-sized Advisors. For Advisors participating in AdvisorAssist's Annual Compliance services, you will be receiving an annual renewal questionnaire that will address these items.

Here's the copy of the SEC Email Distribution:

SEC-Registered Investment Advisers: The revised Form ADV is now programmed into IARD. Between January 1, 2012 and March 30, 2012, all SEC-registered advisers are required to file a Form ADV amendment (annual amendment or other-than-annual amendment), completing all items on the revised form and indicating with which regulator they should be registered. A registered adviser that files an other-than-annual amendment to its Form ADV prior to January 1, 2012 will not be required to complete all of the new items on the revised form (see General Instructions, Instruction 4 for when certain items are required to be updated Please see SEC adopted rules for more information (IA-3221 and IA-3222, June 22, 2011, on You cannot reply to this email. If you have questions, please email IARDLIVE@SEC.GOV.

THIS COMMUNICATION IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND CONTAINS OR MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this communication is not the intended recipient (or the employee or agent responsible for delivering to the intended recipient), you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please disregard and delete this communication, and do not disseminate or retain any copy of this communication.

Open questions on SEC to State Transition?
If you still have open questions regarding your options, timing, securities rules or other aspects of transition to state registration, please schedule a call with us. Please send an email to

Tuesday, November 1, 2011

Annual Chief Compliance Officer Report

Reminder: Annual CCO Report

As a reminder, Rule 206(4)-7 of the Investment Advisers Act of 1940 and related state regulations require that Advisors implement (and maintain) a compliance program that is designed to prevent, detect and correct any violations of the securities laws. 

Also, the Chief Compliance Officer ("CCO") of the Advisor must review the compliance program at least annually to demonstrate compliance with this rule. The regulators expect to see documentation of this effort through testing and an annual assessment. There is no require to deliver any report or output to the regulators, but AdvisorAssist suggests a report to file or memo from the CCO to the CEO or Management. This is still a good practice even in a one person firm.

What should be contained in the report?
The annual CCO report should at least address these four (4) main areas:

  1. What changes have been made to the compliance program since the last annual review (or since inception for a new Advisor)? For instance, did you modify your compliance manual, update the Code of Ethics, change technology? 
  2. Have there been any compliance violations or issues encountered? Examples might include trading errors, failure to make disclosures, missed deadlines, not following your policies and procedures, forgetting to deliver an ADV...(Don't be afraid to document an error. The intent of the rule continuous improvement. It is best to acknowledge an issue, contain it, take corrective action and prevent re-occurrence. 
  3. Any changes to staffing or support? Make note of your relationship with AdvisorAssist and other partners that support your business.
  4. Any changed planned from your review or testing? Do you have any planned changes for the next year? New systems, more training, more staff, outsourcing, a new document management system? Of course only list the items that you intend to commit to.
What format should the report take?

The annual CCO report does not require a specific layout. What is most effective for you to make the exercise worthwhile and actionable? It can paragraph form, bullets, or links to other places where actions are taken. It can be all or any of these items. 

If you have any questions or would like a template, please email us at There are also some tools to help you in the Compliance Advantage Resource Portal at