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Stack #4630716

S27 FINRA Timing

QuestionAnswer
Firm fails to maintain Special Reserve Account – first action? Immediately take corrective action; notify within 24 hours
Tentative net capital drops below early warning level – timing bucket? 24-hour notification bucket
AI exceeds 1 500% – operational consequence?
Net capital deficiency discovered – books adjustment timing? Immediately reflect on books; notify within 24 hours
Box count discrepancy found – when must it be recorded? Within 7 business days of the count
Physical securities count required how often? At least quarterly
Material inadequacy in accounting system – report when? Within 30 calendar days
Change in fiscal year end – notify SEC when? Within 10 business days
Independent accountant resignation – notify within? 10 business days
Failure to obtain required possession or control – notify when? Within 24 hours
Reserve computation deficit discovered – timing bucket? 24-hour bucket
Unresolved securities differences affect net capital when? Within 7 business days of count
Capital problem vs governance change – which is faster? Capital problems are 24-hour; governance is 10-day
Material weakness vs capital deficiency – longer timing? Material weakness: 30 days; capital: 24 hours
Operational halt vs regulatory notice timing? Halt immediately; notify within 24 hours
Early warning capital trigger – regulator notice? Within 24 hours
Audit finding without capital impact – timing? 30 calendar days
Structural firm change filing – typical timing? 10 business days
Box count reconciliation deadline memory hook? Clean the box in 7
Capital distress memory hook? If capital shakes
Capital below minimum – notification timing? Notify regulators within 24 hours; cease doing business immediately
Aggregate indebtedness exceeds 1 200% – notify when?
Alt method firm tentative net capital below $5B – notify when? Within 24 hours
Failure to make required reserve deposit – notify when? Within 24 hours
Unresolved box count differences must be recorded when? Within 7 business days after the count
Change in independent accountant – notify SEC when? Within 10 business days
Material weakness in internal controls – report when? Within 30 calendar days
Capital problems fall into which timing bucket? 24-hour notification bucket
Box count cleanup falls into which timing bucket? 7 business day bucket
Governance/structural changes fall into which timing bucket? 10 business day bucket
Audit/internal control weaknesses fall into which timing bucket? 30 calendar day bucket
Net capital below minimum – operational action? Cease doing business immediately; notify within 24 hours
Monthly FOCUS filing due when? Within 17 business days after month end
Quarterly FOCUS filing due when? Within 17 business days after quarter end
Annual audited financial statements due when? Within 60 calendar days after fiscal year end
FOCUS extension request timing? Must request before due date; SEC approval required
Customer reserve computation frequency? Weekly for most carrying firms
Reserve deposit deadline after computation? No later than 1 hour after bank opens on 2nd business day
Reserve deficiency notification timing? Within 24 hours
Quarterly securities count required how often? At least quarterly
Unresolved box count differences recorded when? Within 7 business days after the count
Change in independent accountant notification timing? Within 10 business days
Material weakness in internal controls reported when? Within 30 calendar days
Net capital below minimum – notify when? Within 24 hours
Net capital below minimum – operational action? Cease doing business immediately
Aggregate indebtedness exceeds 1 200% – notify when?
Alt method firm tentative net capital below $5B – notify when? Within 24 hours
Failure to make required reserve deposit – notify when? Within 24 hours
Possession or control deficiency – notify when? Within 24 hours
Early warning capital trigger – timing bucket? 24-hour notification bucket
Box count cleanup timing bucket? 7 business day bucket
Governance or structural change timing bucket? 10 business day bucket
Audit or internal control weakness timing bucket? 30 calendar day bucket
Reserve deposit memory rule? 2 days plus 1 hour after bank opens
FOCUS filing memory rule? 17 business days
Audited financials memory rule? 60 calendar days
Customer complaint definition? Any written statement alleging a grievance involving activities of the firm or associated person
Oral complaint count requirement? Oral complaints are not counted as reportable customer complaints
Customer complaint record retention? Retain for at least 4 years; first 2 years in an easily accessible place
Customer complaint reporting on FOCUS? Certain complaints must be reported on FOCUS filings
Complaint involving theft or misappropriation – reporting timing? Report within 30 calendar days
Complaint alleging forgery – reporting timing? Within 30 calendar days
Complaint alleging securities law violation – reporting timing? Within 30 calendar days
Internal complaint log must include what? Complainant name
OSJ complaint file requirement? Each OSJ must maintain a separate complaint file
Complaint statistics reviewed by whom? Supervisory personnel as part of compliance oversight
Customer complaint memory rule? Written equals record; serious equals 30 days
Is email a written complaint? Yes; email qualifies as written complaint
Are social media messages written complaints? Yes
Anonymous written complaint handling? Must be retained and logged if written
Customer complaint retention clock starts when? Date complaint is received
Created by: sjameve
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