Compliance Rules Grid

Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)

Supervisory

SystemDesignation of Principals – FINRA rules 3010(a)(2); 3010(b)(3)

Heightened Supervision

Producing Manager Review

FINRA Rule 3012(a)(2))C) if

App.

Annual Review of Key Contacts

– FINRA rule 1150

Supervisory Control System FINRA rules 3012 (a) (1) Testing the

Firm's Written Supervisory Procedures to Ensure that All Rules are

Addressed

Supervisory Control System FINRA rules 3012 (a) (2) (i-iv) Identifying

Producing Managers and Assigning Qualified Supervisors FINRA Rule

3012(a)(2))C)

Review of Outsourcing

Activities to Third-Party Service

Providers – FINRA rule 3010

Annual Compliance and Supervision Certification – FINRA rule

3013(b)

Supervisory Control System FINRA rules 3012 (b) (2) (i) (ii) Supervision

of Transmittal of Customer Funds or SecuritiesReview of Businesses – FINRA rule 3010©

Supervisory Control System FINRA Rule 3012(a)(2)(B) Supervision of

Customer Changes of Address - Annual Compliance Meeting or Interview – FINRA rule 3010(a)(7)

Supervisory Control System FINRA Rule 3012(a)(2)(B) Supervision of

Customer Changes of Investment Objective -Form BD and Membership Agreement – FINRA By-Laws Art. IV,

Section 1

Supervisory Control System FINRA Rule 3012(a)(2)(A)(ii) Use of the

Limited Size and Resources Exception for Branch Manager Supervision,

Including the Factors Used in Determining the Exception is Necessary -

Annual Review of Key Contacts – FINRA rule 1150

Heightened Supervision Procedures -FINRA Rule 3012 (a)(2)C)

Designation of Chief Compliance Officer –FINRA rule 3013(a)

Designation of Contact Persons – FINRA rule 1150

Determining Qualifications of Supervisory Personnel – FINRA rule

3010(a)(6)

Designation of Principal Responsible for Supervision of Form Filings –

FINRA rule 1140

Assignment of Registered Persons – FINRA rule 3010(a)(5)

Supervisory Personnel Record including titles, registration status and

locations – SEC rule 17a-3(a)(12)

Distribution of Procedures and Amendments – FINRA rule 3010(b)(4)


Form BD and Membership Agreement – FINRA By-Laws Art. IV, Section

1

Designation of Persons Responsible for Explanation of Books and

Records– SEC rules 17a-3 and 17a-4 & FINRA rule 3110

Records of Reports - Records of Procedures and Manuals

Soft Dollars – SEC Section 28(e)

Approval of Outsourcing Activities to Third-Party Service Providers –

FINRA rule 3010

Compliance Announcements of Rule Updates

SRO Inquiries

Branch Office

ActivitiesLocations at which the Firm Conducts Business – FINRA rule 3010(c)(1)

Inspection Schedule for Locations at which the Firm Conducts

Business – FINRA rule 3010(c)(1)

Rules Applicable to Supervision of Non-OSJ Branch Office Activities -

FINRA rule 3010 ©Annual OSJ Inspection – FINRA rule 3010 ©

Periodic Review of Non-Branch Location - FINRA rule 3010 © Branch Office Inspection - FINRA rule 3010 ©

Supervision of Non-Branch Business Locations - FINRA rule 3010 ©

Broker-Dealer Activity on Premises of Financial Institutions – FINRA rule

2350

Personnel

Matters

Proper registration and Disclosures to New Hires/Terminations, Periodic

reviews exam scheduling coordination etc. – FINRA rule 3080

Ongoing Personnel Registration

– Periodic Review – FINRA rule

1120

Outside Business Activities - Initial and Annual Attestation – FINRA

rule 3030

Fingerprinting – SEC rule 17f-2 and FINRA rule 1140Organization Chart Update

Review

Private Securities Transactions - Initial and Annual Attestation –

FINRA rule 3040


Background Investigations – FINRA rules 3010(a)(6) and 3010(e)Monitor compliance with

regulatory element 1120

Continuing Education – Needs Analysis Assessment – FINRA rule

1120

Proper Registration Upon Hire - FINRA By-Laws, Article III, Section 2;

FINRA rules 1070; 1021; 1022; 1030; 1040; 1100; & 1110

Continuing Education – Training Plan and Materials - FINRA rule

1120

Ongoing Personnel Registration – Changes in Duties – FINRA rule 1120Continuing Education – Maintain records of attendance - FINRA rule

1120

Personnel Files Identification Numbers or Codes Continuing Education – Designate CE contact with FINRA

Parking of Securities Registrations – FINRA rule 1031(a)

Supervision of Statutorily Disqualified Individuals – FINRA By-Laws,

Article III, Sections 3 and 4; FINRA rule 3070

Termination of Registration - FINRA By-Laws, Article III, Sections 3 and 4

Continuing Education – Regulatory Element – FINRA rule 1120

Outside Business Activities - Initial Request – FINRA rule 3030

Outside Business Activities - Initial and Annual Attestation – FINRA rule

3030

Private Securities Transactions - Requests & records of – FINRA rule

3040

Compensation Arrangements and Employee Agreements Compensable

Transactions

Customer Complaints – FINRA rule 3110

Reporting of complaints, actions etc. – FINRA rule 3070


Insider Trading Restricted ListsTrading in Advance of

Research – FINRA IM 2110-4Chinese Walls Insider Trading Training

Monitoring for Insider Trading, update employees on new rules for insider

trading

Restricted List -Compliance

Review

Front Running – FINRA IM-

2110-3Insider Trading Require employee to sign attestation NTM-91-45

Financial

ReportingFinOp Training – NTM 06-23, 1022(b); 1022©,

Net Capital Computation (Trial

Balance) – SEC rules 15c3-1

and 17a-11

Net Capital - Part I - SEC rules

15c3-1 and 17a-11

Net Capital - Part II - SEC rules

15c3-1 and 17a-11FinOp Assessments – NTM 06-23

FinOp Periodic Reviews – NTM 06-23FinOp Periodic Reviews (NTM

06-23)Audited Financials - SEC rules 17a-5 and 17a-11

On-Site Documentation – NTM 06-23Charges for services performed-

FINRA rule 2430

Net Capital - Early Warning - SEC rules 15c3-1 and 17a-11

Material Inadequacy - SEC rule 17a-5(g)(3)

Designation of Accountant - SEC rule 17a-5(f)(4)

Customer Reserve – SEC rule 15c3-3

Handling Customer Funds and Securities - SEC rules 17a-5 and 17a-11

Lost and Stolen Securities - SEC rules 17a-5 and 17a-11

Margin Requirements – FINRA rule 2520 Cash Account Provisions of

Reg.-T

FINRA Fees and Assessments- FINRA By-Laws Schedule A

Charges for services performed – FINRA rule 2430


Mandatory Electronic Filings – FINRA rule 3170

Customer

AccountsAcceptance of New Accounts – Customer Approval

Exception Reports (Pershing)

FINRA 3230© NTM 99-57

Prohibition Against Guarantees -

FINRA rule 2330(e)

Changes of Customer Address

FINRA Rule 3012(a)(2)(B)

Customer Account Statements

(2340)SIPC Disclosure

Acceptance of New Accounts - Imposition of Credit LimitsMarkups and Commissions -

FINRA IM-2430, 2440

Spot Check Clock

Synchronization - FINRA rule

6953

Changes of Customer

Investment Objectives FINRA

Rule 3012(a)(2)(B)

Investor Education & Protection 2280

Accounts for Persons Associated at Other Broker/Dealers – FINRA rule

3050

Transaction Monitoring,

Account Reviews

Trade reporting by 3rd parties if

applicable

FINRA Compliance Report

Cards

Furnishing Account Information to Customers

Trade Reporting

ACT/OATS/TRACE Reporting

FINRA rule 6130

Periodic Review of Open

Accounts 3010(d)

Records of Customer Agreements General Fails & DKs Account Activity - review

Borrowing From or Lending to Customers – FINRA rule 2370

Account Designation Changes – FINRA rule 3110(j)

Changes of Address- FINRA rule 3110(j)

Mail - FINRA rule 3110(i)

Churning – FINRA IM-2310-2

Customer Account Statements & Order Tickets– FINRA rule 2110, 10b-

10, 11Ac-3,2320,2830,3110, SEC Rule 17a-3(a)

Risk Management (financial or credit account level or credit breaches)

Dealing with

Customers and

Activities of RR's

Suitability of Recommendations – FINRA rule 2310Daily Review of Accounts -

FINRA rule 3010©

Ongoing Personnel Registration

– Periodic Review – FINRA rule

1120

Unauthorized Trading – FINRA

IM-2310-2

Gifts and Gratuities – Approval

Process - FINRA rule 3060Employee and Related Accounts - FINRA rule 2110


Markups and Commissions - FINRA IM-2440Employee and Related

Accounts - FINRA rule 2110

FINRA Contact Information

review FINRA rule 1150

Reg SP Privacy and Opt-out notifications, including procedures for

ensuring customer information is safeguarded, ensure proper

disposal of consumer report information

Approval of Account Name or Designation Changes for Orders - FINRA

rule 3110Continuing Education Updates

Trading in Advance of

Research (FINRA 2110)

Registration of Research Analysts FINRA 1050, 2711, NTM 07-04,

NTM 0481, NTM 04-18

Prohibition Against Guarantees - FINRA rule 2330(e) Research Quit Periods FINRA 2711, 2210

Gifts and Gratuities – Aggregation of Gifts - FINRA rule 3060

Gifts and Gratuities – Business Entertainment

Accounts Maintained at Other Broker-Dealers - List of Personal Accounts

at Time of Hire – FINRA rule 3050

Accounts Maintained at Other Broker-Dealers - Receipt of Statements

and Confirms – FINRA rule 3050

Employee and Related Accounts - FINRA rule 2110

Reg SP Privacy and Opt-out notifications, including procedures for

ensuring customer information is safeguarded, ensure proper disposal of

consumer report information

U-4/U-5 or Form BD Disclosures or Updates

Communication

with the Public

Advertising & Sales Literature - (including e-mail & websites) FINRA rule

2210

Outgoing Written

Communication - FINRA rule

3010(d)

Outgoing Electronic

Communication - FINRA rule

3010(d)

Institutional Sales Literature & correspondence - FINRA rule 2211

Incoming Written

Communications - FINRA rule

3010(d)

Incoming Electronic

Communications - FINRA rule

3010(d)

Speaking Engagements, scripts, outlines - FINRA rule 2210Instant Messaging (Bloomberg) -

FINRA rule 3010(d)

"Internal Use Only" Material not released to Public


Cold-Calling - FINRA rule 2210

Payment for Order Flow - FINRA rule 2110

Fixed Income Securities

Trade Reporting Securities Parking Review – FINRA rule 2110

Trade reporting –

ACT/OATS/TRACE FINRA

Rule 6130

Best Execution - FINRA rule

2320

Clock Synchronization - FINRA

rule 6953

Adjusted Trading: Trade Errors, Commission Adjustments & Position

Logs

Timely Acceptance and Entry of

Trades Reportable by Other

Firms – FINRA rule 6130

Comparison of OATS and ACT

Data – FINRA rule 6954

Best Execution – Routed Orders – FINRA rule 2320

Correctly Marking and reporting

a Sale as Long, Short, or Short

Exempt – SEC rule 203, FINRA

rule 6130

Interpositioning – FINRA rule 2320

OATS Data Accuracy -

Monitoring the Accuracy and

Timeliness of OATS

Submissions by Third Parties -

FINRA rule 6954

Trade reporting – FINRA rule 6130

Correction and Re-submission

of Data Rejected by OATS –

FINRA rule 6954

Riskless Principal Trade Reporting – FINRA rule 6130

Anti-Competitive Practices – SEC 21(a) Report and FINRA IM-2110-5

Transmitting OSO Agreement - FINRA rule 6954

OATS Announcements of Updates from FINRA.ORG

Handling of Customer Orders During Market-Wide Trading Halts

Records of Executions


Business

Continuity

Emergency Contact Persons, Significant Business Disruptions ("SBD"),

Plan Location and Access, Clearing Firm

Daily Data Backup (Hard &

Electronic Systems)

Weekly Data Backup (Hard &

Electronic)

Monthly Data Back-Up

(Electronic)

Quarterly Data Back-Up

(Electronic)Approval and Execution Authority

Office Location(s), Alternative Location (s) Updates and Annual Review

Customer' Access to Funds and Securities

Data Back-Up (Hard Copy)

Data Back-Up and Recovery (Hard Copy and Electronic)

Operational Risk

Financial and Credit Risk

Mission Critical Systems

Clearing Firm Responsibilities

Recovery Time

Order Taking

Order Entry

Order Execution

Alternative Communications – Customers


Alternative Communications – Employees

Business Constituents-Banks

Counter-Parties

Regulatory Reporting

Disclosure Statement

Anti-Money

LaunderingAML Procedures - Amendments 3011

Providing AML Information to

federal Law Enforcement

Agencies and Other Financial

Institutions - FinCEN Requests

Under PATRIOT Act Section

Wired Funds/Securities (AML) AML Compliance Program - Approval 3011

*all elements required

even if considered

"NA" to business

AML Procedures - List of Entities Covered Restricted by FinCEN Special

Measures

FinCEN Requests Under

PATRIOT Act & Bank Secrecy

Act Section 314 bi-weekly

Annual Audit Independent Test 3011

Firm’s AML Policy Senior Manager Approval of AML Program

AML – AML Compliance Officer Designation and Duties AML-Contact Person

Providing AML Information to federal Law Enforcement Agencies and

Other Financial Institutions - Sharing Information With Other Financial

Institutions US Patriot Act, Section 314

Checking the Office of Foreign Assets Control (“OFAC”) List

Customer Identification and Verification -Required Customer Information

NTM 03-34

Customer Identification and Verification - Customers Who Refuse To

Provide Information

Customer Identification and Verification - Verifying Information


Customer Identification and Verification - Lack of Verification

Customer Identification and Verification - Comparison with Government

Provided Lists of Terrorists and Other Criminals

Customer Identification and Verification - Notice to Customers

Customer Identification and Verification - Reliance on Another Financial

Institution for Identity Verification

Foreign Correspondent Accounts and Shell Banks - Detecting and

Closing Correspondent Accounts of Foreign Banks and Shell Banks

Private Banking Accounts/Foreign Officials

Transaction Monitoring, Account Reviews

SAR Filing - Responding to Red Flags and Suspicious Activity

Currency Reporting and Wire Transfers - Generally

Currency Reporting and Wire Transfers - Currency Transaction Reports

Currency Reporting and Wire Transfers - Currency and Monetary

Instrument Transportation Reports

Currency Reporting and Wire Transfers

Foreign Bank and Financial Accounts Reports (“FBAR”)

Filing currency transaction reports CTR's Bank Secrecy Act


Ongoing Training

Confidential Reporting of AML Non-Compliance

Monitoring Employee Conduct and Accounts

Senior Manager Approval of AML Program

Compliance Rules Grid

Business

Transcript of Compliance Rules Grid