Alert ID: 166 2/6/2014
Suggested Routing:
Legal & Compliance
Senior Management

Annual Amendment and FINRA Entitlement User Accounts
Certification: Where to Begin?

The Securities and Exchange Commission (SEC) Investment Advisers Act of 1940 rule 204-1 [17 CFR 275.204-1] requires every investment adviser to file an annual amendment no later than 90 calendar days from their designated fiscal year-end. Assuming that your firm has a December 31 year-end, the deadline for receipt of the annual amendment by the respective recipient of the report is March 31, 2014.

To complete the annual updating amendment, make sure that you choose to file an Annual Updating Amendment as the type of filing to be submitted on the Investment Adviser Registration Depository (IARD) and review and update the entire Form ADV prior to submitting the filing.

You will not be able to submit your annual updating amendment filing unless you have the requisite funds in your IARD Flex-Funding Account to cover the filing fee. The amount of the filing fee varies by assets under management and the schedule is available on the SEC<>) and IARD (<>) websites.

With regards to the FINRA Entitlement User Accounts Certification, you should have received an email from FINRA stating that the records indicate that as of February 2, your firm's Super Account Administrator (SAA) had not yet completed the 2014 FINRA Entitlement User Accounts Certification process.

All Super Account Administrators must review their firm's FINRA Entitlement user accounts to verify that:

*   each user has a continuing need to access FINRA application(s) on the organization's behalf;

*   each user is entitled only to the applications and privileges needed to perform current job responsibilities; and

  *   only users who require access to sensitive data (e.g., Criminal History Record Information, Social Security or tax identification numbers, dates of birth) are entitled to access this type of data.

In the event user accounts are not certified by February 12, 2014 all of your firm's administrators will lose the ability to create, edit and clone accounts until the certification process has been completed. In addition, firms that fail to certify may be referred for follow-up by the appropriate regulator.

If you need any assistance in completing annual amendment or FINRA Entitlement User  Accounts Certification process, or have questions regarding the annual amendment or certification process, please feel free to contact us.   Firms desiring assistance may contact Kristy Johnson, Senior Associate at (281) 367-0380 or

  MGL Consulting LLC
33300 Egypt Lane, Suite E400
Magnolia, Texas 77354
Phone: 281-367-0380

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