Tuesday, November 18, 2014

FINRA Security Update - Changing Administrator (SAA)

FINRA is finally catching up with the realities of cybersecurity. They are implementing much needed verification controls to ensure that the Super Account Administrator ("SAA") cannot be changed without proper authorization. Prior to 11/19/14, FINRA would provide access to anyone that mailed or faxed them a document (without any real verification). Yes - your social security and personal information has been at risk for a long time!

Below is a summary of the FINRA communication.


Effective November 19, 2014, FINRA will implement new controls to enhance the security of the entitlement process for firms seeking to replace their Super Account Administrator (SAA) or update a current SAA’s information. If your firm is not seeking to change its SAA or update the name or email address of the current SAA, no action is required at this time.

Under the new entitlement process, firms must complete an Update/Replace SAA Form to replace or update the name or email address of their current SAA. This new form is not available online and must be requested by an Authorized Signatory of your organization by contacting FINRA’s Gateway Call Center at (240) 386-4848.

For more information on Authorized Signatories for firms and how to update or replace an existing SAA on or after November 19, please visit the FINRA Entitlement Program – Super Account Administrator page.

If you have any questions, please contact AdvisorAssist at support@advisorassist.com.

Tuesday, November 4, 2014

FINRA E-Bill Enhancements (Refunds & Alerts)

FINRA is finally adding some needed features to their E-Bill system.

Effective November 4, 2014, FINRA has updated E-Bill to allow entitled users to request a refund from the Advisor's Flex-Funding Account via E-Bill. Also, you can now subscribe to receive email alerts related to your firm's CRD Renewals Account, such as when the preliminary or final renewal statement is available, when a final statement is paid in full and when a final statement is due. To configure these alerts, go to the Alert Settings tab on E-Bill.

As always, if you have any questions, please email us at support@advisorassist.com.

Client Geography Review

As we prepare for annual renewal season, we strongly suggest that you run a client geography report to determine if you have clients outside your home state that exceed the de minimis threshold for that state.

Most states have set the de minimis threshold at 5 clients, meaning, if you do not have a place of business in that state, you may have up to 5 clients before you need to register or notice file. The are four (4) states that are exception, including:

  • Louisiana
  • Texas
  • Nebraska
  • New Hampshire

These states generally require firms to notice file (SEC) or register (state) prior to doing any business. Investment Advisor Representatives may also be required to register.

AdvisorAssist will analyze your geography report and determine which states you are required to be registered based on the report and the nuances of the various state regulations. You can submit these reports from your Advisor Portal under Compliance Activities > Submit Support Request.

It is best to complete these reports prior to November 10, 2014, as Preliminary Renewal Statements are released by FINRA on that date.

If you have any questions, please contact your AdvisorAssist consultant or email us at support@advisorassist.com.