Thornton & Associates wanted to let you know that FINRA announced a new contact name in your FINRA Contact Questionnaire titled Chief Information Security Officer (CISO).

The CISO role is defined as:

“Person at your firm responsible for establishing and maintaining the enterprise vision, strategy and program to ensure information assets and technologies are adequately protected, or person closest to that role.”

The rules for identifying the CISO role are as follows:

1. Your firm is not required to list an individual on the FINRA contact questionnaire. It is voluntary and the decision to list an individual is completely at your discretion. If you would like us to identify a CISO on the questionnaire we would be happy to do so. It is our position that identifying a CISO will not help or hurt you from a regulatory perspective.

2. If you choose to identify a CISO, that individual is not required to hold a principal designation with the firm;

3. If you decide to list a CISO, only one person can be listed. This differs from other positions listed in the FINRA Contact Questionnaire which require both a primary and secondary contact; and

4. The CISO is not included in the Annual Contact Questionnaire review and update.

Please feel free to contact us at (626) 356-0200 if you have any questions.

FINRA’s 2016 Regulatory and Examination Priorities Letter

The SEC has approved a rule to establish a new Form Custody that all registered broker-dealers must file at specified times with their designated examination authority. Firms will be required to file the Form Custody when they submit their Focus filings. The first Form Custody filings, which will be for the period ending Dec. 31, 2013, are due Jan. 27, 2014. These filings will be due each quarter on the same day that the FOCUS Reports are due. Click here to learn more.

Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2013 – Amends the Securities Exchange Act of 1934 to allow merger and acquisition brokers (M&A brokers) who perform services in connection with the transfer of ownership of smaller privately held companies to register with the Securities and Exchange Commission (SEC) by filing an electronic notice.

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