BD Financial Services Group has relationships with qualified Financial and Operations Principals interested in registering and providing services to firms on a contract basis. Rates vary depending on services provided, however, affiliated FINOP’s will register with your firm, prepare monthly net capital computations, file FOCUS reports, and send a monthly file complete with supporting documents.
BD Financial Services Group assists broker-dealers with regulatory issues related to SEA Rule 15c3-1, “the Net Capital Rule”. Areas of expertise include rule interpretation and implementation, financial systems development, accounting and accounting procedures, accounting software application and initialization, financial statement compilation, net capital computation and FOCUS reporting.
Regulatory bodies, including the SEC, FINRA and state regulatory agencies will review a broker-dealer’s net capital as part of each examination. It is not unusual for regulators to detect discrepancies that may or may not lead to violations, but in most instances will require changes to the firm’s books and records and revision to net capital computations. BD Financial Services Group principals are experienced assisting broker-dealers with accounting and net capital problems and will assist the firm with responses to Rule 8210 requests related to any accounting or net capital issues.
In addition to providing assistance with issues related to net capital, BD Financial Services Group principals combine their knowledge and application of the rules with technical and professional writing expertise essential to addressing all other regulatory concerns, limiting further requests and reducing potential exposure.
FINRA Rule 3310 requires that each broker-dealer undertake annually an independent AML test for compliance. Such testing is to be conducted by member personnel or by a qualified outside party. Members that do not execute transactions for customers or otherwise hold customer accounts or act as an introducing broker with respect to customer accounts (e.g., engages solely in proprietary trading or conducts business only with other broker-dealers), are required to undertake “independent testing” every two years (on a calendar-year basis).
BD Financial Services senior partner has in excess of twenty-five years financial institution senior management compliance experience and has provided consultative services to professionals in the legal and financial profession related to interpretation of the SEC Act of ‘33 and ‘34, the Maloney Act, the Investment Advisors Act of 1940, the Bank Secrecy Act, GAAP, SEC requirements that exceed GAAP, corporate governance and general business matters. Our manager was involved in the implementation of the Bank Secrecy Act requirements at NASD member firms and has been engaged in anti-money laundering procedures and testing since inception of the requirement. In 2014, he met with and reviewed his qualifications and test format with staff of the SEC in Ft. Worth, Texas. There were no concerns or objections to his qualifications or the test format.
PCAOB has issued guidance to its registered auditors that restricts the auditors ability to compile certain financial statements, footnotes and supplemental reports. According to PCAOB the auditors preparation of these items would be considered management functions and would therefore impede upon the auditors independence. It is now the responsibility of the broker-dealer to prepare the complete set of financial statements, footnotes and supplemental reports including, computation of net capital, SIPC reports and other materials relevant to the broker-dealers audit. BD Financial Services Group is prepared to assist the FINOP’s of its clients by preparing the complete set of financial statements, footnotes and supplemental reports for delivery to the auditor for his/her review.
BD Financial Services Group operates as an associated partnership created by an investment-banking professional who has acted as Chief Financial and Operations Principal and Chief Compliance Officer with significant senior-level financial and compliance experience. Affiliated and associated partners include former FINRA/NASD/SEC compliance examiners, Certified Public Accountants, and attorneys practicing in various areas including private securities law, dispute resolution, and hearings and appeals proceedings with FINRA and the SEC. Our principals have significant experience establishing, developing, and managing broker-dealers engaged in general securities, investment banking and asset management. BD Financial Services Group assists broker-dealers, investment advisors, and often other broker-dealer consultants by drawing upon its diverse partners and associates. We provide our clients with relevant interpretation, effective defenses, and initial compliance controls, and, when necessary, developing a defense to mitigate the consequences of actual or perceived industry non-compliance; allowing our clients to spend their time operating their businesses and making money… not answering 8210 requests and allocating significant resources to appeasing regulators.
BD Financial Services Group partners, associates and affiliates are all extremely well-qualified and experienced in relevant areas of compliance-related services. Whether your broker-dealer is currently undergoing a regulatory exam, has undergone an exam and is being cited and/or requested to respond, or is proactive and attempting to remain in compliance, our team can assist you by customizing a suitable compliance program review. Areas of compliance practiced by BD Financial Services Group affiliates include FINRA Rules, SEC Rules, NFA, CFTC and RIA.
All FINRA members are required to have, maintain and update, on an as-needed basis, but no less than annually, written supervisory procedures that are specific to the business in which it conducts and the processes and procedures it employs.
Each FINRA member is required to develop and implement a written anti-money laundering program reasonably designed to achieve and monitor the member’s compliance with the requirements of the Bank Secrecy Act. BD Financial Services Group partners perform fully electronic AML testing.
Rule 8210 requires FINRA members to respond to regulatory requests. With over twenty-five years responding to regulatory requests for information evidence indicates that a well-written professional response by consultants with expert knowledge of the rules and regulations can mitigate potential damages, and in many cases, with cause regulators to dismiss their attempt to assert a violation where none actually occurred.
Rule 3130 (formerly 3012/3013), FINRA members are required to undertake a detailed review of the broker-dealers supervisory control procedures and have a report certified by management. The review must include a review of certain aspects relevant to the broker-dealer, including, but not limited to a review of supervisory systems, identification of producing managers and heightened supervisory procedures related thereto, small firm exemption filings, review of adequacy of supervisory procedures and a certification related thereto.
Each registered representative and principal is required to participate in an annual compliance meeting relevant to the firm’s type of business. The meeting can be held collectively or individually, but must be documented and relevant to the types of business that is conducted by the broker-dealer. It is beneficial to have the meeting cover areas and/or provide training in such things as Anti-Money Laundering and continuing education. All aspects of the Annual Compliance Meeting must be properly document the topics discussed, the format and evidence attendance.
Rule 17a-5(d) requires every broker or dealer registered pursuant to section 15 of the Act to file annually, on a calendar or fiscal year basis, a report which shall be audited by a PCAOB registered independent public accountant. FINRA members must file an Annual Audited Report not more than 60 calendar days after the date selected for their fiscal year end. Additionally, all FINRA members who are members of SIPC and who are required to file Annual Reports pursuant to SEC Rule 17a-5(d)(1), 17 C.F.R. § 240.17a-5(d)(1), must also file a copy of their Annual Reports electronically with SIPC. Email the Annual Reports to SIPCAuditReports@sipc.org, and in the subject line, please include the SEC 8- number, the name of the member, and the fiscal year end for the Annual Reports.
BD Financial Services Group is not a CPA firm or PCAOB-registered accounting firm and though it does provide various financial services it does not conduct audits or provide accounting services. BD Financial Services Group does, however, work with PCAOB-registered CPA’s that are committed to providing broker-dealers with high quality, independent audits. BD Financial Services Group understands that small, independently-owned broker-dealers are primarily interested in receiving a compliant audit at a very competitive price, being able to communicate with the auditor regarding the progress and status of the report and receiving the report in a timely fashion.
The principals of BD Financial Services Group are prepared to discuss your audit needs, and, when requested, to assist its clients and client’s auditors to facilitate the compilation and/or completion of the report.
BDFSG partners assist companies with business development and management issues such as choosing an organizational structure and developing a business plan to providing ongoing services including bookkeeping and tax.
Tax planning should successfully and legally reduce your tax liability and is a key component to a unified strategic business process. BD Financial Services Group goes beyond tax compliance and proactively recommends tax saving strategies to maximize your after-tax income.
By diligently assisting you to assure tax compliance, BD Financial Services Group will help you to meet your obligations; avoiding penalties and minimizing risks associated with costly tax examinations.
BD Financial Services Group will take the time to review your entire personal and business operations and immediate and long-term goals to prepare and deliver cost-effective measures.
BDFSG associates provide many services, including the following:
- Individual Tax Preparation
- Business Tax Return Preparation
- Partnership & Corporate Tax Preparation
- Financial Statement Tax Provision Calculation per GAAP
- Tax Planning
- Out-of-State Returns
- Business Start-Ups
Development of an accounting system prior to conducting business is of paramount importance. BD Financial Services Group can design and help implement an appropriate accounting system and procedures that will meet your business needs. Our objective is to set up an efficient, understandable accounting system for all our clients to assist in any way with the financial operation of your business.
BD Financial Services Group has your solutions, whether your company simply needs us to manage the books or help to smooth out financial issues that may occur. We can assist you in creating a managerial accounting manual and thereafter provide consulting services to help you keep within your budget. Additionally, we have the ability to provide monthly bookkeeping services and provide you and your FINOP with the information you need each month.