Areas of Specialization

Market Access

 

Appropriate systems, procedures, data and records for trading operations relating to Direct or Sponsored market access and Regulation SHO have been of increasingly prominent focus to FINRA and the various exchanges. Year after year, both FINRA and the SEC signal their emphasis within its Examination Priorities. Hundreds of millions in fines have been levied on market participants. Yet, without clear regulations and guidance, stakeholders may continue to run deficient processes at the risk of penalties and reputational costs. Through our operative expertise and extensive interactions with the regulators, we have been able to identify implicitly acceptable guidelines, considerations and lines of emphasis directly related or adjacent to market access controls or surveillance.

Digital Asset Securities

 

Digital Asset Securities is an emerging asset class that, through its association with the ‘blockchain,’ has garnered exhaustive scrutiny by FINRA’s Digital Asset committee and the SEC’s Division of Trading & Markets. Though different models have been floated, and some approved by the SEC and FINRA, the uncertainty around custody of such securities have prevented many firms from operating in the most efficient manner. We have worked closely with the SEC’s Trading & Markets and FINRA’s Digital Asset committee on the build-outs of the various custody models, including banks, transfer agents, introducing to a clearing firm, self-clearing and even cryptocurrency custody through a broker-dealer.

Clearing Broker Operations

 

The economic trends of the broker-dealer industry have incentivized more participants to become correspondent-, omnibus- or self-clearing brokers. For these entities, it critical to understand how to appropriately implement the systems, reporting, calculations and books and records in order to become and remain compliant with the Customer Protection Rule as well as other relevant regulations and capital requirements associated with clearing. Our associates have successfully built, implemented or audited clearing operations of all types and are uniquely positioned to assist with such projects.

Personnel

 

Keenly aware that client success is not merely dependent on reaching the end of a project with us, but, rather, on the continuous execution of the day-to-day duties in the operation of the broker-dealer. Understanding that the implementation of a procedure is only as good as the person assigned to it, it is imperative to associate only with the most knowledgeable, detail-oriented and proactive staff. To that end, we provide the independent contract services of our associates whom are of the utmost quality, experience and diligence. Such personnel possess excellent communication skills and hold the requisite securities licenses where appropriate.

Technology

 

Utilization of the proper technology is a pre-requisite for any operation within the securities industry. A significant part of our engagements involve consultancy on the various systems that will bring about compliant results, especially within the clearing, market access and digital securities business lines. Among others, we function as a bridge to developers, provide scope and logic for back office systems as well as financial and surveillance reporting. Our staff also assists with securing the necessary third-party vendors and integrating such vendors into the client systems. Finally, we also support programs relating to vendor management and data quality.