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Industry Challenge

Under FINRA’s newly consolidated registration rules that went into effect October 1, 2018, firms may permissively register or maintain the registration of any associated person, including individuals working solely in a clerical or ministerial capacity, which is an expansion of previous categories for permissive registrations.
Firms are required to:

  • Possess adequate supervisory systems and procedures reasonably designed to ensure that individuals with permissive registrations do not act outside the scope of their assigned functions.
  • Supervise the activities of these individuals consistent with the requirements of FINRA Rule 3110 (Supervision), including the assignment of an appropriately registered supervisor under FINRA Rule 3110(a)(5) who is responsible for supervising their activities.
  • While firms are not required to assign a registered person as the day-to-day supervisor of an individual who solely maintains a permissive registration, for purposes of compliance with FINRA Rule 3110(a)(5), firms are required to assign a registered supervisor who will be responsible for periodically contacting the individual’s day-to-day supervisor to verify that the individual is not acting outside the scope of his or her assigned functions. Firms must ensure they have the proper tracking systems in place to track permissive registrations and status, as well as the facility for tracking both the registrations that are categorized as permissive and the registered supervisor that is assigned to each.

    RegEd Solution

    RegEd’s Xchange and Compliance Questionnaires solutions provide a comprehensive, WORM-compliant system for managing permissive registrations using a highly configurable workflow and approval process, including:

  • The management of permissive registrations and associated status
  • The supervisory tracking as required by FINRA 3110(a)(5)
  • The collection, tracking and recording of attestations
  • Administrators may track and report on both partial and full permissive registrations for their registered rep population. Tracking includes status and effective dates as well as associated supervisory information to ensure the proper management of the permissive population.
    You may customize RegEd’s standard Permissive Registration Attestation form to fit your firm’s needs, and drive increased efficiency and supervisory control using custom, hierarchical-driven workflows and review statuses. Regularly scheduled attestations ensure up-to-date and accurate information across your registered population while the system ensures a full audit trail is logged and properly recorded.

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