Attorneys in the Corporate & Finance Group have provided regulatory and compliance counseling to a broad subsection of the broker-dealer community, including online brokerage firms, independent contractor networks, traditional full service firms, market-making firms, and clearing firms. The types of services provided by this group include:

• Setting up internal inspection programs for independent contractor networks, including providing training sessions and materials for internal auditors; accompanying firm personnel on initial audits; and reviewing audit documentation during the programs’ initial period;
• Updating and enhancing written supervisory procedures and internal controls; presenting the new procedures and internal controls to firm personnel; and conducting periodic question-and-answer sessions on regulatory and compliance issues;
• Conducting internal audits of retail sales practices, books and records, financial controls, and other aspects of brokerage firm business and preparing confidential reports thereon for firm management;
• Providing all services necessary to obtain federal and state broker-dealer registration and NASD membership, including preparation of all necessary filings, preparation of written supervisory procedures, setting up internal financial systems and controls, and participating in the NASD pre-membership interview;
• Formulating and drafting responses to deficiency letters resulting from regulatory examinations; and
• Analyzing and, where appropriate, obtaining informal or formal guidance from regulatory authorities on a broad range of broker-dealer compliance issues.