SEC Asks for Help Understanding Digital Assets and Custody Rule, FINRA Issues FAQs on 529 Self-Reporting Request, and New Testing for Swap Traders

Hardin Compliance Consulting LLC

For Investment Advisers: SEC Actions

Mr. Blue Skies:  A Primer on Form D and Blue Sky filings:  For hedge fund and private fund managers, Denise Alfieri provides an overview of the basics of Form D and blue sky filings.  Check out The Devil is in the Details:  A Primer on Form D and Blue Sky Filings for Private Fund Managers.  Contributed by Denise D. Alfieri, Managing Director

Speak Now or Forever Hold Your Peace — SEC Asks for Help on the Custody Rule:  Advisers:  Now is your chance to speak up! The SEC is re-evaluating certain aspects of the Custody Rule (Advisers Act Rule 206(4)-2) and wants public comment on trading practices, including trades that are not settled on a delivery versus payment (“Non-DVP”) basis and the application of the Rule to digital assets.  In the release, the SEC lists questions where it wants industry and public input.

DVP settlement is “cash on delivery,” where payment is made when the security is delivered to the client’s account, making it difficult for a custodian to misappropriate client funds. Assets that settle Non-DVP, such as peer-to-peer transactions that settle on a Blockchain, are potentially more vulnerable to misappropriation.  “The Staff expects to utilize what it learns in future recommendations to the Commission.” Comments can be provided to the SEC using the email address with “Custody Rule and Non-DVP Trading” or “Custody Rule and Digital Assets” in the subject line.  Contributed by Heather D. Augustine, Senior Compliance Consultant.

For Broker-Dealers:  FINRA Actions 

Keeping up with  FINRA’s 529 Plan Share Class Initiative:  Recently, FINRA released another video segment, “A Few Minutes With FINRA,” and Frequently Asked Questions Regarding the 529 Plan Share Class Initiative, where it announced an extension to the deadline for self-reporting to April 30, 2019.  In turn, FINRA extended the confirmation of eligibility deadline to May 31, 2019.  Firms may now request extensions for both the self-reporting and confirmation of eligibility due dates, via email to

Susan Schroeder, EVP of Enforcement, addressed several questions received by FINRA in response to its 529 Plan Initiative, all the while stressing that this is a voluntary initiative.  When deciding whether to self-report, firms are encouraged to conduct a quality assessment of their supervisory procedures rather than a quantitative analysis.  Firms should ask whether they have the information needed to supervise these transactions and whether their brokers are properly trained to make appropriate share class recommendations.  If a firm identifies deficiencies in its supervisory procedures related to 529 Plan share class recommendations, even if there has been no impact to clients, the firm is encouraged to self-report to FINRA the corrective measures being taken to strengthen supervision in this area.

Ms. Schroeder also stated that self-reporting may not always result in an enforcement action.  For example, in cases where a firm identifies supervisory deficiencies but determines there has been no impact on customers, the results may be cautionary or no-action.

To assist you with assessing the quality of your supervisory procedures, Hardin has created a checklist of factors to consider.  Contributed by Rochelle A. Truzzi, Senior Compliance Consultant

Registration Required If Your Firm Handles Orders in NMS Stocks, OTC Equity Securities, or Listed Options:  Rule 613 under the Securities Exchange Act of 1934 requires national securities exchanges to create a National Market System (“NMS”) plan to develop a consolidated audit trail (CAT) that allows regulators to track activity in U.S. equity and options markets.  CAT NMS, LLC was formed by FINRA and other market participants to develop a database for all equity and options trading on U.S. exchanges.  FINRA firms that handle orders in NMS stocks, OTC (over-the-counter) equity securities or listed options will have to register as CAT Reporters by June 27.  Under the CAT NMS Plan, firms may self-report, use a third-party vendor to report, or use a combination of the two reporting methods.   Registration is now open and is due by June 27, 2019.   All subject firms must register, regardless of their reporting methods.

Registration is easy and must be completed on-line through the CAT NMS Plan website. Information requested includes: a registered principal, the manner of data submission (self-reporting or via a vendor), preferred reporting method (SFTP or via the CAT Reporting Portal), and the size of the firm (whether it has a capitalization of $500,000 or less).  The form also requires a CAT Reporting Industry Member ID number.  For your reference, FINRA hosted an industry webinar on March 19th and established a web page regarding the consolidated audit trail.  Please bookmark the Consolidated Audit Trail website for information on future developments and the Plan timeline.   Contributed by Rochelle A. Truzzi, Senior Compliance Consultant

Attention FINOPs – How To Report Operating Leases on FOCUS Filings:  In February 2016, the Financial Accounting Standards Board (“FASB”) released amendments to the accounting standards for recognizing leases on the balance sheet of a lessee (Topic 842, “Lease Accounting Update”).  The amendments went into effect for some firms that have fiscal years beginning after December 15, 2018.  The Lease Accounting Update changed the treatment of operating leases by requiring that a lessee must include on its balance sheet an asset and liability arising from an operating lease.  In response, the SEC issued a second No-Action Letter to Securities Industry and Financial Markets Association (SIFMA) dated October 23, 2018 (SIFMA 2 No-Action Letter) which pointed out that under the net capital requirements for broker-dealers in Securities Exchange Act Rule 15c3-1, an operating lease asset would be a non-allowable asset for purposes of determining net worth.   Without relief, a broker-dealer lessee would need to deduct the operating lease asset from its net worth when computing net capital.  The SIFMA 2 No-Action Letter grants such relief when a firm, in calculating net capital, adds back to its net worth an operating lease asset to the extent of the associated liability (with certain restrictions).  On the other side of the T-account, a firm does not need to include in its aggregate indebtedness calculation an operating lease liability to the extent of the operating lease asset (with certain restrictions).  This no-action letter replaces a prior No-Action Letter to SIFMA dated November 8, 2016.

In Regulatory Notice 19-08, FINRA provides specific guidance for reporting lease assets and lease liabilities on FOCUS reports.  The Lease Accounting Update requires a lessee to include on its balance sheet an asset and liability arising from an operating lease.  The SIFMA 2 No-Action Letter states that the SEC will not recommend enforcement action under Rule 15c3-1 if a firm, when calculating net capital, adds back to its net worth an operating lease asset to the extent of the associated liability (with certain restrictions).  On the other side of the T-account, a firm does not need to include in its aggregate indebtedness calculation an operating lease liability to the extent of the operating lease asset (with certain restrictions).  Contributed by Rochelle A. Truzzi, Senior Compliance Consultant

Does Your Firm Publish Quotations in Unregistered Securities of Foreign Private Issuers?  If so, FINRA’s Regulatory Notice 19-09 is a must read!   As per Securities Exchange Act Rule 15c2-11, a firm is prohibited from publishing quotes on such securities unless it has obtained, reviewed and makes available upon request the current (since the beginning of its last fiscal year) information published (or required to be published) by the issuer, including:

  • information that has been made public according to the laws of the issuer’s country of incorporation;
  • information filed with the principal stock exchange in the issuer’s primary trading market; and
  • information distributed to security holders.

This information is required by Securities Exchange Act Rule 12g3-2(b)(1)(iii) and must be available in English.  Member firms can satisfy this requirement if they provide the requestor with instructions on how to access this information on the issuer’s website.  The firm needs to be sure that the issuer’s web site does not restrict U.S. residents from this information.  Contributed by Rochelle A. Truzzi, Senior Compliance Consultant

For Mutual Funds: SEC Actions

Modifications to Form N-PORT: In response to information security concerns, and given the large amount of sensitive fund data contained on Form N-PORT filings, the SEC has issued an interim final rule (the “Interim Rule”) modifying Form N-PORT reporting requirements.  Under the Interim Rule, large and small fund complexes will still be required to prepare Form N-PORT within 30 days after month end.  But they will only be required to file the prior three month’s reports within 60 days after the fund’s fiscal quarter end.  Only the final month in the quarter will be publicly available.  The table below outlines the updated effective and filing dates.  Form N-LIQUID has also been amended to include an optional explanatory note.  Contributed by Cari A. Hopfensperger, Senior Compliance Consultant

No Action Letter to the Independent Directors Council relaxes certain in-person voting requirements for fund boards:  In a commonsense move, the SEC lifted the in-person meeting requirement for certain mutual fund board actions.  The relief permits directors to meet via telephone or video conference to vote on the following board actions:

  • Approval of an investment advisory contract under Section 15(c) of the Investment Company Act;
  • Approval of the principal underwriting contract for the fund;
  • Selection of the Fund’s independent accountant; and
  • Renewal of the fund’s 12b-1 plan.

The relief granted is limited to situations where the renewal or approval does not include material changes.  Contributed by Cari A. Hopfensperger, Senior Compliance Consultant

For Municipal Advisors: MSRB Actions

MSRB Announces Effective Date for Amended Advertising Rules: On February 26, the MSRB announced amendments to MSRB Rule G-21, on advertising by brokers, dealers, and municipal securities dealers, and new Rule G-40, on advertising by municipal advisors.  These changes become effective on August 23, 2019.  The MSRB also announced two related rule changes that will become effective on the same date.  The changes provide social media guidance under the advertising rules and exempt interactive content considered to be advertising from the principal pre-approval requirements.  Contributed by Doug MacKinnon, Senior Compliance Consultant.

For Hedge Fund Managers: CFTC Actions 

NFA to Require Swap Proficiency Testing:  Beginning in 2021, associated persons of registered Commodity Pool Operators (CPOs) and Commodity Trading Advisors (CTAs) that engage in swap activities must satisfy new Swaps Proficiency Requirements similar to those required of associated persons engaging in commodity futures or forex activities.  To acknowledge the different types of swap activities performed, NFA established two separate tracks – a Long Track and Short Track.  According to the release, the requirements will need to be completed online through various modules that contain training and testing components.  The NFA has outlined the proficiency requirements in greater detail on its website.  Contributed by Cari A. Hopfensperger, Senior Compliance Consultant.

IA Watch Webinar on Real-Life Lessons on BCPs with Jill Grenda, Managing Director at Hardin Compliance Consulting:  Don’t miss IA Watch’s FREE webinar, Real-Life Lessons Learned from Peers Who’ve Had to Implement their BCPs on April 16  from 2:00 p.m. to 3:00 p.m. EDT.  This webinar features several CCOs sharing their real-life experiences, including Hardin Compliance Consulting Managing Director, Jill Grenda.  Other speakers include Maurice Tallini, CCO Domini Impact Investments; Deborah Lamb, CCO McKinley Capital Management; and Ken Hyman, CCO Partnervest Advisory Services.

Highlights include:

  • What the SEC expects of you when it comes to your BCP
  • Why even the best BCP may force you to improvise in an emergency
  • Advice on how best to test your BCP and train employees to react properly
  • Ideas to add to your BCP

Register for IA Watch‘s FREE webinar and earn 1 CLE/CPE/CFP credit.

Photo Credits: Photo by Johannes Plenio on Unsplash

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