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Launching a broker-dealer
We take a broker-dealer from business plan through the FINRA new member application to the first day of business, and stay with the firm through its first year and first exam.
Where we start
The application follows from a few decisions: the business lines, the customers, the clearing model and the ownership. Each one shapes the capital, the people and the procedures the firm needs, and each is harder to change after approval, so we settle them first and build the plan from there.
The application
Business plan and projections
Each business line, the financial projections, the organizational chart and the documentation behind the funding.
Form BD and state registrations
Filed through CRD for the SEC and each state where the firm will do business.
New member application
Filed through FINRA Gateway with the supporting documents, including procedures, financials, the clearing agreement and leases.
Review and membership interview
Responses to staff requests and preparation of the principals for the interview.
Approval and membership agreement
The agreement that sets the firm's approved business until a continuing membership application changes it.
Ready for business
SIPC, exchange memberships and identifiers as needed, CAT reporting, and testing of every system before the first day.
What we prepare
| Workstream | What we do |
|---|---|
| Business plan | Write the plan around the business lines and customers, with projections that support the capital and staffing in the application. |
| Clearing and banking | Compare clearing firms and models for the business, review the agreement terms, and set up the bank relationships. |
| Capital | Size the capital to the business plan with the FINOP, and build the net capital and financial reporting process. |
| People | Map the required principals and registrations against the team, close the gaps, and introduce FINOPs and compliance consultants where needed. |
| Procedures and programs | Written supervisory procedures, AML, business continuity, books and records, communications review and cybersecurity, written for this firm's business. |
| Systems and vendors | Order management, archiving, surveillance and trade reporting, selected and connected before approval. |
| The interview | Preparation of each principal for the membership interview and the questions staff are likely to ask about the plan. |
After approval
- The first yearSupport through the first FOCUS filings, annual audit, supervisory testing and certification.
- An annual calendarBuilt around the firm's own filings, reviews and testing.
- The first examPreparation, document production and remediation of anything it finds.
- GrowthContinuing membership applications for new business lines and ownership changes.