Broker-dealer & FINRA
This practice was built by someone who formed a FINRA member firm, obtained its membership, and then served as both its chief executive officer and its chief compliance officer. It is not defense-only. Most of it is the work that happens before anything goes wrong.
Proactive, not just defensive.
Firms usually call at one of three moments: forming or changing the business, preparing for an examination, or responding to something that has already landed. All three are easier when the supervisory system was built to be read by a stranger.
The letter everyone dreads
Illustrative · not a real notice
A request under FINRA Rule 8210 arrives. It asks for documents, information and testimony. It has a deadline. It does not explain what the staff thinks happened, and it will not.
The instinct is to answer quickly and completely, to look cooperative. The better instinct is to answer completely, on time, and only after understanding what is actually being asked and what the firm’s own records will show.
Failing to respond is its own violation. Responding carelessly is its own problem. There is a correct middle, and it is worth a phone call.
Services
- Formation and registration of broker-dealers, including new membership applications.
- Rule 1017 applications for changes in ownership, control or business operations.
- Written supervisory policies and procedures — drafted to match what the firm actually does.
- Regulatory inquiry and examination assistance.
- Internal investigations and risk assessments.
- Customer complaint response.
- Product due diligence on offerings the firm is considering.
- Branch office and registered representative reviews.
- Training, compliance and rule interpretation.
- Operations and marketing communication review.
Who calls
FINRA member firms and their principals. Chief compliance officers who need a second reader. Registered representatives facing a complaint, a termination or a Form U5 problem. Firms buying, selling or restructuring a broker-dealer. Sponsors who need to understand what the selling firm is obligated to do.
Related practice areas
Did something
arrive in the mail?
Do not send the letter itself yet. Tell us what kind of letter it is and roughly when it is due, and we will tell you quickly whether this is the right desk.
Start the conversationFootnotes
- The notice reproduced above is an illustration written for this website. It is not a real regulatory communication and does not describe any actual matter.
- General information only, not legal advice. Deadlines in regulatory matters are real and unforgiving; if you have one, speak to a lawyer rather than a website.