Changes have been made to the Entitlement Program which requires action by your investment adviser firm.
As you may know, the Financial Industry Regulatory Authority (“FINRA”) administers the IARD and CRD systems for investment adviser firms on behalf of the U.S. Securities and Exchange Commission and state securities regulators, and the Entitlement Program allows an investment adviser firm to access to the IARD and CRD systems for purposes such as filing the Form ADV and Form U4.
In the past, FINRA required an investment adviser firm to designate a primary and secondary contact for the investment adviser firm’s Entitlement Program. Now, an investment adviser firm must designate a single individual as the firm’s Super Account Administrator (“SAA”). FINRA should have sent reminders regarding this requirement directly to the existing Account Administrator of your investment adviser firm. The deadline for an investment adviser firm to submit the SAA form to FINRA is November 30, 2010. If your investment adviser firm has not already established entitlements for an individual Super Account Administrator, you should complete and submit the SAA Form by no later than November 30, 2010. The SAA Form can be accessed by clicking here.
The Super Account Administrator will be FINRA’s sole contact for the investment adviser firm and will be responsible for ensuring that all FINRA Entitlement procedures and policies are followed. The SAA will also be able to manage users’ accounts on behalf of the investment adviser firm. Only one SAA is permitted per ID/CRD number. An investment adviser firm with multiple affiliates may designate the same SAA for each affiliate, but a separate SAA Entitlement Form is required for each affiliate.
Posted by Bryan Hill