FINRA has proposed a new rule that would require carrying and clearing members to maintain certain records in a central and accessible location in order to facilitate liquidation or transfers of customer accounts.  The records may be maintained electronically, although they must be “uniquely tagged and appropriately indexed so as to be readily identifiable as such.”  The records must be accessible and/or kept within the firm’s principal office.  Required records include a description of all accounts and ranges on the general ledger including associated persons assigned, mapping of the general ledger accounts to trial balances, description of all critical systems, list of bank accounts, executed agreements with clearing agencies, clearing banks, and custodians, and significant outsourcing agreements.  Each firm must designate a contact person responsible for maintaining the records.

OUR TAKE: Although this Rule would only apply to carrying and clearing firms, the requirements serve as good “best practices” recordkeeping for all firms.

 

Todd Cipperman, Esq.
Cipperman & Company
500 E. Swedesford Road
Suite 104
Wayne, PA 19087
610.687.5320
tcipperman@cipperman.com
www.cipperman.com

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