Broker-dealer industry hot topics

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1 Broker-dealer industry hot topics Highlights from Grant Thornton LLP s broker-dealer industry symposium On June 19, 2012, Grant Thornton hosted a panel discussion on the major issues facing the broker-dealer industry. The discussion was hosted by Nichole Jordan, the firm s National Banking and Securities Industry leader. It was moderated by Lee Pacchia, legal analyst and host of Bloomberg Law multimedia programs. The panel comprised several brokerdealer industry professionals, including these industry experts: Steven Lofchie, partner, Cadwalader Kevin Piccoli, deputy director, Division of Swap Dealer and Intermediary Oversight, U.S. Commodity Futures Trading Commission (CFTC) Lanny A. Schwartz, partner, Davis Polk & Wardwell LLP Grace Vogel, executive vice president of member regulation, Financial Industry Regulatory Authority (FINRA) The following are edited transcripts and summaries of panel discussions from the conference. In all cases, the speakers comments represent their own views and are not necessarily those of their respective organizations, Grant Thornton LLP or its clients, or any other entity. The information provided may not and should not be construed to imply endorsement or even support by Grant Thornton LLP of the views expressed herein. The panelists addressed a number of current issues facing the broker-dealer industry. The issues discussed included environmental pressures, changes in the regulatory atmosphere, enhanced customer protection rules, and margin changes and technology changes, including the use of social media. Environmental pressures The discussion stressed that the two major drivers that impact the industry relate to the inability of broker-dealers to address liquidity and collateral certainty. Effective implementation of the rulemaking and regulatory initiatives discussed here is dependent on adequately addressing these issues.

2 Basel III Recent financial crises have highlighted weaknesses in the global regulatory framework for financial firms. As a result, the Basel Committee on Banking Supervision has adopted the global regulatory standard known as Basel III. It covers bank capital adequacy, stress testing and market liquidity risks. The Basel III initiative will put increased pressure on broker-dealers profitability, particularly on returns on equity (ROE) given the increased capital and margin requirements. Balance sheets will also be reduced because of increased leverage requirements. One of the challenges broker-dealers are facing under Basel III is how to replace or increase their revenues to maintain the ROEs that shareholders have come to expect. From a sales practice perspective, regulators are concerned that new products originally developed for institutional clients are now being sold to retail customers, which may not be appropriate for them. According to Panelist Grace Vogel, while all the regulations governing the securities business took many years to develop, the regulations governing the derivatives space evolved over a much shorter period of time. And, she observed, as swaps move to execution facilities and central clearing under the new guidelines, margins to dealers will be dramatically reduced. Regulators have been challenged to find the appropriate model to determine the amount of capital that has to be maintained by broker-dealers. The value-at-risk model for trading assets is currently in use, but according to Vogel, that model presents challenges because it is accurate only 99 percent of the time. This means that one out of every 100 days will result in a loss that exceeds the model, Vogel said. As a result, the SEC and the CFTC have set minimum capital requirements. Under its Consolidated Supervised Entity program, the SEC required that broker-dealers have at least $5 billion in tentative net capital (i.e., net liquid assets). However, this proved to be insufficient in the case of Lehman Brothers in 2008, when a lack of liquidity exposed the firm s inability to realize the measured fair value. Vogel indicated that FINRA is now placing much more focus on liquidity, asking firms to maintain sufficient liquidity at the broker-dealer level rather than at the holding company, and to perform stress testing to ensure liquidity is available when needed. While currently there are no definitive SEC rules governing liquidity, Vogel expects to see some liquidity rules for securities-based swap dealers proposed this summer. Dodd-Frank implementation (Uniform Fiduciary Standard) Under Dodd-Frank, the SEC is mandated to study the need for establishing a uniform federal fiduciary standard of care for broker-dealers and investment advisers who provide personalized investment advice. According to Vogel, FINRA believes a fiduciary standard is appropriate for all customers, including brokerage customers. However, FINRA does not believe every client is suitable for a feebased account, which may result in higher charges, and does believe clients should have the option to have a self-directed account for which they are charged on a commission basis. In a fee-based account, the customer is generally charged separately for each service provided, while a commission charge is incorporated into the transaction itself. The proposed Investment Adviser Oversight Act suggests shifting the regulation of investment advisers from the SEC to FINRA. Panelist Lanny Schwartz indicated that the topic of self-regulation for investment advisers has been around for many years. He agrees that there are important customer benefits. This was highlighted in part by the Madoff crisis, when the principal regulator the SEC did not have sufficient manpower to perform timely examinations of the more than 12,000 advisers. (The SEC did perform an audit of the Madoff broker-dealers, although the extent of the clients who had invested in Madoff-managed accounts through other advisers was the examination failure issue.) According to Schwartz, as the broker-dealer and investment advisory businesses converge, utilizing FINRA as the selfregulatory organization (SRO) for investment advisers would promote a common set of standards and approaches for examinations. While the SEC has revised its custody examination requirements, installing an SRO would support improvements to investment adviser examinations. The proposed Investment Adviser Oversight Act suggests shifting regulation of investment advisers from the SEC to FINRA.

3 JOBS Act regulation The Jumpstart Our Business Startups (JOBS) Act that was recently passed by Congress brings two major reforms to securities law: changes to the IPO process and facilitation of capital access to private companies. But what are the consequences for brokerdealers on the research side? Panelist Steven Lofchie sees a contradiction in the regulation; for example, the CFTC has been tightening its regulation of institutional research on interest rates and FX, while the SEC is deregulating research on emerging growth companies meant for retail investors. Schwartz pointed out that the legislation is an example of the trade-offs that come with securities regulation, because the JOBS Act may allow small businesses to more easily raise capital and access the IPO market. Uncertainty regarding the Volcker Rule The Volcker Rule has created uncertainty for financial institutions and the financial markets in general. Lofchie sees difficulty in regulating non-u.s. financial institutions because that effort may negatively affect international relations with these institutions and could affect U.S. jobs. He also sees diminished liquidity and widening spreads in the market. On the other hand, Vogel does not believe liquidity will be affected, indicating that there are many market makers that can provide liquidity not subject to the Volcker Rule. Risk review update Panelist Kevin Piccoli indicated that liquidity is one of the main risk factors driving firms into troubled situations. He anticipates pressure on U.S. firms, particularly the parent companies of futures commission merchants (FCM), as a result of downgrades on some banks coupled with the European situation. It is important to understand the risk elements in order to keep customers funds safe and secure. From an examination standpoint, Piccoli noted that the CFTC will be taking a closer look at the risk profiles of firms and the effect on customers. Segregation and secure control locations for customer funds Piccoli said that the CFTC will be recommending changes to the method of computation for secured funds. FCMs should be using the net-liquidating equity method to compute the secured amount versus the alternative method, which can leave any unused portion of customers funds exposed to loss. Piccoli indicated that the CFTC will be issuing a letter to FCMs in the near future, addressing computation methods. He expects some regulations regarding secured funds to be forthcoming. He also mentioned that the CFTC is contemplating whether FCMs should be required to disclose the location of the secured assets and to what extent that location should be made available to the public. Proposed elimination of credit ratings in SEC rules Under Dodd-Frank, the SEC has proposed removing references to credit ratings within the credit agency rules and, where appropriate, replacing them with an alternative standard of creditworthiness. Vogel said that no-action letters making reference to credit ratings will continue to exist, but the SEC is planning to change the language where reference is made to a nationally recognized statistical rating organization. Importance of broker-dealers custody practices Lofchie emphasized the importance of the custody rule for brokerdealers and advised firms to take a closer look at their foreign control location agreements. He added that the treatment of affiliate accounts is a very important issue. Vogel commented that there have been instances in which firms have lost significant amounts of money because they did not review transactions closely enough; the transactions were masked because they were done on an intracompany basis.

4 Additional areas of focus FINRA Rule 4524 (Rule 4524) Rule 4524 allows FINRA to collect information supplementary to the Financial and Operational Combined Uniform Single (FOCUS) report. According to Vogel, the FOCUS report is an SEC form, first approved in the mid-70s, that has become outdated. The SEC has recently approved Rule 4524, which allows FINRA to collect information supplementary to the FOCUS report. Each form must go through the comment period and rulemaking process; the first form that was approved is a detailed income statement that must be filed by every firm on a quarterly basis, with the first filing due for the period ending Sept. 30, This information will give FINRA a better understanding of how the firm is making money and what its expenses are. FINRA will also require additional information from firms that, during a reporting period, derive more than 10 percent of their total revenues from participation in unregistered offerings. The second form, which is applicable only to carrying and clearing firms, is a proposed supplemental off-balance sheet schedule, designed to give better insight to off-balance sheet items. In the case of MF Global, several risks were not detected because they were off-balance sheet items and were identified only after the annual audited financials were released. There were some concerns regarding the confidentiality of the schedule, but Vogel assured the audience that FINRA does not make the FOCUS report available to the public, and therefore would not make the supplemental schedule available either. Proposed additional documented procedures for clearing firms Proposed FINRA Rule 4516 will require clearing, carrying and self-clearing firms to store certain records (e.g., lists of responsible parties, access letters to all control locations, detailed procedural write-ups) in a centralized physical location at the principal office to enable regulators to take prompt action to protect investors in the event of a liquidation. After receiving comments from member firms, FINRA is making some modifications to the proposed rule, including narrowing the universe of firms subject to the rule. Use of social media and areas of concern With the proliferation of social media use by broker-dealer personnel, FINRA has developed detailed guidance for member firms. Any communication made with the public falls under SEC rules and must be supervised and retained by the brokerdealer. A registered principal (principal) must approve the use of any social media site prior to its use by an associated person. Any communication that recommends certain products may trigger the suitability rule, and additional disclosures may be required. Certain social media meet the definition of a public appearance, such as participation in online forums, chat rooms and seminars. While these actions do not need prior approval, a post-review would be required. Blogs that contain certain static content fall under the SEC s advertising rules and require principal review prior to use. Use of Facebook, Twitter and LinkedIn also need to be supervised, and depending on how the associated person is using them, may require pre- or post-review. Third-party posts are also an area of concern because they could be attributed to the firm. Any links to a thirdparty also raise concerns because these sites may contain misleading or incorrect information. The use of personal devices by broker-dealer personnel is also an area of uneasiness. Vogel referred to it as Bring Your Own Device because many firm personnel do not want to carry several devices and prefer to be able to access all of their work on their own personal device. The brokerdealer needs to be able to retain and supervise all of the activity on that device. Many firms are asking personnel to sign an annual attestation of compliance with firm polices.

5 Proposed efforts to increase customer protection As self-regulatory organizations for the futures commission, the National Futures Association and the Chicago Mercantile Exchange merchants have proposed rule amendments to increase customer protection. In addition, Piccoli said the CFTC is expecting each firm s chief compliance officer (CCO) to take an active role in ensuring the right areas are being reviewed. The CFTC is proposing that CCOs of swap dealers and FCMs perform an annual certification stating that policies, procedures and controls have been reviewed and are in position. This proposed rule is similar to FINRA Rule 3130, which requires CEOs or their equivalent to annually certify firm compliance policies and supervisory procedures. The CFTC will also be focusing on the amount of excess in the funds required to be segregated or secured. This amount is traditionally viewed as the cushion, or as Piccoli called it, the target level. Firms will now be required to disclose how the target level is determined, and they will be required to notify the CFTC if there are changes in the level, and why. If more than 25 percent of the excess is withdrawn, this action must be approved by the CEO or CFO. FINRA Rule 5310 (Best Execution Rule) FINRA Rule 5310 (Rule 5310) is the new consolidated rule governing members best execution requirements. Moderator Lee Pacchia asked whether Rule 5310 will provide more comfort to investors, and if regulators are focused on the right issues. Lofchie feels that the equity markets are incredibly efficient, with very little fluctuation in price one way or another. Additionally, Lofchie feels there are other issues, such as liquidity, that are more deserving of attention from firms and regulators. From a regulatory perspective, he thinks that best execution practices are a relatively low regulatory priority. Creation of swap data repository and areas of concern Under Dodd-Frank, market participants particularly swap dealers need to report certain data elements to a registered swap data repository or the CFTC. The industry has many concerns about the structure, including the ability of firms to gather all the information required in the time frame put forth by the rule. There are also concerns about the swap data repositories themselves, including how they operate, what their technical standards are and the security of the data. Given the complexity of the swaps data, Schwartz voiced concern over how intelligible the information will be and how market participants will be required to use it. Information learned from the May 6 flash crash On May 6, 2010, the Dow Jones fell almost 700 points in less than 30 minutes in an event dubbed the flash crash. Pacchia asked what we have learned from it. Vogel indicated that there is a more rational uptick rule that should prevent the same thing from happening again, as well as SEC Rule 15c3-5, which is the direct-market access rule requiring firms to put controls in place. High-frequency traders (HFT) and potential restrictions According to Vogel, HFTs argue that they provide liquidity to the market. However, she said it is often difficult to distinguish between an HFT and a market maker. Lofchie feels that the SEC has taken away a lot of the incentive to be a market maker, and by default, the HFTs have become market makers. Given the complexity of the swaps data, Schwartz voiced concern over how intelligible the information will be and how market participants will be required to use it.

6 Status of SEC rules The SEC is working on finalizing the new Form Custody report, which wil require information about how a broker-dealer maintains custody over customer and noncustomer assets. Vogel said she expects the new form to go into effect in the first quarter of The SEC is also planning to adopt a rule requiring a report from auditors indicating compliance with SEC Rules 15c3-1, 15c- 3-3 the customer protection rule and 17a-13, which requires a broker-dealer to count the securities it holds for customers and for itself. Furthermore, the SEC is planning to adopt a rule that would require auditors to speak directly to the SEC to review their risk assessment processes. The principal message from our panel of experts is to properly assess liquidity and provide adequate levels of capital to sustain a firm in troubled times. Firms should constantly verify their ability to timely recover assets maintained in separate control locations, regardless of the legal status. Inclusion of previously unregistered derivative entities as major swap participants Piccoli indicated that it will be interesting to determine who actually qualifies as a major swap participant. The CFTC currently anticipates 125 swap dealers will be registered, some of which have never been registered before. Piccoli said the CFTC will work with these entities to determine best practices and to develop testing methods the entities can understand. Contact information For more information about the topics covered at this event, contact one of our professionals: Nichole Jordan National Banking and Securities Leader Grant Thornton LLP T E nichole.jordan@us.gt.com Jack Katz National Managing Partner Financial Services Grant Thornton LLP T E jack.katz@us.gt.com Visit Grant Thornton LLP All rights reserved U.S. member firm of Grant Thornton International Ltd Content in this publication is not intended to answer specific questions or suggest suitability of action in a particular case. For additional information on the issues discussed, consult a Grant Thornton client service partner. The people in the independent firms of Grant Thornton International Ltd provide personalized attention and the highest quality service to public and private clients in more than 100 countries. Grant Thornton LLP is the U.S. member firm of Grant Thornton International Ltd, one of the six global audit, tax and advisory organizations. Grant Thornton International Ltd and its member firms are not a worldwide partnership, as each member firm is a separate and distinct legal entity. In the U.S., visit Grant Thornton LLP at

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