On January 28, 2019, FINRA released its Regulatory Notice 19-04 announcing its 529 plan self-reporting initiative. This initiative is part of FINRA efforts to have broker-dealers promptly remedy potential supervisory and suitability violations related to recommendations of share classes for 529 plans.
To encourage self-reporting, for a limited time FINRA will offer favorable settlements where violations are found. These terms include no fine and no designation of “statutory disqualification.” However, the deadline to give FINRA notice that you intend to engage in the 529 plan self-reporting initiative is 12:00 a.m. Eastern time on April 1, 2019. Therefore, time is of the essence. This initiative is further detailed in the Drinker Biddle Client Alert linked below.
Read More: FINRA’s 529 Plan Share Class Initiative to Self-Report
Earlier this month, FINRA published its Annual Regulatory and Examination Priorities Letter (the “Letter”). This is the first Letter under the tenure of new FINRA President and CEO Robert W. Cook. Notably, Mr. Cook introduced FINRA’s annual Letter with his own “cover letter” in which he shared several thoughts with the broker-dealer industry, including a common thread running through FINRA’s Letter—specifically a focus on core issues of compliance, supervision, and risk management. Mr. Cook also discussed his “listening tour” to meet with member firms, regulators, and investor groups since joining FINRA in August. In doing so, he shared two takeaways. First, starting this year, FINRA will publish summary reports that outline key findings from examinations in selected areas to serve as additional tools that firms can use to strengthen their controls. Second, in response to feedback from smaller firms, FINRA … Read More »