SEC FLASH REPORT. June 28, 2011

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1 SEC FLASH REPORT The Securities and Exchange Cmmissin Issues Prpsal t Strengthen Audits and Reprting f Brker-Dealers t Prtect Custmer Assets and Requests Cmments June 28, 2011 On June 15, 2011, the U.S. Securities and Exchange Cmmissin (SEC) issued prpsed rules designed t increase regulatry versight f brker-dealers custdy f custmer assets. The prpsed amendments t the brker-dealer financial reprting rules are intended t strengthen the audits f brker-dealers as well as the SEC s versight f the way brker-dealers handle their custmers securities and cash. The SEC s prpsal builds upn rules adpted in 2009 that strengthened the prtectins prvided t investrs wh give custdy f their assets t investment advisers. The cmment perid n the prpsed amendments is pen until August 26, The SEC s prpsal emphasizes several pints. The first area f amendments wuld strengthen versight f brker-dealer custdy practices by requiring certain brker-dealers (i.e., thse that maintain custdy f custmer assets r clear transactins fr themselves r ther firms) t allw SEC staff and the relevant designated examining authrity (regulatrs) t review wrking papers f the public accunting firm that audits the brker-dealer s financial statements and discuss any findings with the accunting firm. This prtin f the amendments is limited in scpe t assisting the regulatrs with their examinatins f brker-dealers and is nt intended t psitin them t review the independent auditr s wrk, which is the respnsibility f the Public Cmpany Accunting Oversight Bard (PCAOB). The secnd set f prpsed amendments requires each brker-dealer t file a Cmpliance Reprt declaring it has implemented sund internal cntrls t cmply with SEC Rules 15c3-1 Net Capital Cmputatin, 15c3-3 Custmer Prtectin Reserves and Custdy f Securities, and 17a-13 Accunt Statement Rule (cllectively, the Financial Respnsibility Rules). These amendments als require the independent auditr t file a Cmpliance Examinatin Reprt stating that it has examined the assertins made by the brker-dealer in its Cmpliance Reprt. The third area f amendments wuld increase reprting f brker-dealers custdy f custmer cash and securities practices thrugh the filing f a new Frm Custdy n a quarterly basis. This quarterly filing wuld elicit infrmatin abut the custdy practices f the brker-dealer that will be used as a starting pint fr examinatins by regulatrs. The Ddd-Frank Act authrizes the PCAOB t inspect public accunting firms that audit brkerdealers and enfrce adherence t applicable audit standards. It is imprtant t nte that this prpsal prvides the fundatin fr the PCAOB t establish new brker-dealer audit standards. Differences in standards frm generally accepted auditing standards (GAAS) include dcumentatin standards and the requirement fr an Engagement Quality Review. Accunting

2 firms wuld be required t prvide pinins n the brker-dealer s cmpliance and internal cntrl ver cmpliance with key regulatry requirements cvering the entire fiscal year and nt just at year-end. The discussin belw utlines the SEC s prpsal in greater detail. Annual Reprting Amendments The prpsal wuld require the brker-dealer t file a new Cmpliance Reprt and the related filing f a Cmpliance Examinatin Reprt issued by the brker-dealer s independent accunting firm. This prpsal satisfies bth SEC Rule 17a-5, Reprts t Be Made by Certain Brkers and Dealers, and the Investment Advisers Custdy Rule with the preparatin f ne reprt. The three types f reprts cvered by the SEC prpsal are discussed further belw: (1) Cmpliance Reprt This reprt must include an assertin that the brker-dealer s system f internal cntrls prvides reasnable assurance that any instances f material nncmpliance with the Financial Respnsibility Rules will be prevented r detected timely. The reprt wuld include three assertins with respect t the Financial Respnsibility Rules: Cmpliance with all material respects f the Financial Respnsibility Rules as f the end f the brker-dealer s fiscal year Whether infrmatin used t assert cmpliance with the Financial Respnsibility Rules was derived frm the bks and recrds f the brkerdealer Whether internal cntrl ver cmpliance with the Financial Respnsibility Rules was effective during the mst recent fiscal year and that there was n material weakness in such internal cntrls during the fiscal year In additin, if there is a material weakness in internal cntrls r any instances f material nn-cmpliance with the Financial Respnsibility Rules, the weakness r nncmpliance must be described in the Cmpliance Reprt. This reprting requirement addresses nly the afrementined Financial Respnsibility Rules and des nt extend further t the general financial reprting requirements f brker-dealers. Als, the prpsed rule is intended t fcus nly n the brker-dealer s custdial respnsibilities t its custmers. The term, material nn-cmpliance, wuld replace the current term, material inadequacy, in Rule 17a-5. Material nn-cmpliance is defined as a failure t cmply with the Financial Respnsibility Rules in all material respects. The term, material weakness, is defined as a deficiency r cmbinatin f deficiencies in internal cntrl such that there is a reasnable pssibility that material nn-cmpliance will nt be prevented r detected in a timely manner. This definitin is similar in wrding t the definitin f material weakness in financial reprting cntrls. The prpsed rules state that a deficiency in internal cntrl exists when the brkerdealer s nrmal peratins wuld nt prevent r detect the event in a timely manner. The prpsal states that there is a reasnable pssibility f an event ccurring if it is either prbable r reasnably pssible. An event is prbable if it is likely t ccur, Prtiviti 2

3 and reasnably pssible if the chance f ccurrence is mre than remte, but less than likely. T address the questin f hw t assess materiality, the prpsed rules suggest several cnsideratins: With respect t instances f material nn-cmpliance: Nature f the cmpliance requirement, e.g., it may nt be quantifiable in mnetary terms Nature and frequency f nn-cmpliance events Qualitative cnsideratins, e.g., needs and expectatins f the reprt users T illustrate, material nn-cmpliance includes, but is nt limited t, failure t maintain the required minimum amunt f net capital and failure t maintain the minimum depsit requirement in a special reserve bank accunt fr the exclusive benefit f custmers under SEC Rule 15c3-3. With respect t a material weakness in internal cntrl: Whether it is reasnably pssible that the cntrl deficiency r deficiencies culd result in material nn-cmpliance The SEC pints ut that it is pssible t have a material cntrl deficiency even where n material nn-cmpliance event has ccurred. In additin, the cmmissin asserts in its prpsal that an instance f nn-cmpliance that the brker-dealer has determined des nt cnstitute material nn-cmpliance may nnetheless be indicative f a cntrl deficiency that cnstitutes a material weakness. This evaluatin wuld require the brker-dealer t cnsider nt nly the specifically identified instance f nncmpliance, but als any additinal pssible effect that the cntrl deficiency r deficiencies culd have n cmpliance. The SEC states that the brker-dealer may nt assert effective internal cntrl if ne r mre material weaknesses exist regarding internal cntrls ver cmpliance with the Financial Respnsibility Rules. (2) Exemptin Reprt Under the current prpsal, brker-dealer firms that d nt carry custmer accunts r clear transactins, i.e., intrducing r crrespndent brkers, can file an Exemptin Reprt. This reprt wuld assert the brker-dealer s exemptin frm the requirements f Rule 15c3-3. (3) Cmpliance Examinatin Reprt This reprt wuld be issued by the brker-dealer s independent public accunting firm t describe the results f its examinatin f the assertins made by the brker-dealer in the Cmpliance r Exemptin Reprt. Frm Custdy Amendments The prpsal prvides the regulatrs with specific and detailed infrmatin n the surces f custmers being carried n the bks f the brker-dealer and the lcatins where thse custmers assets are maintained. Surce f custmers Fr example, ther brker-dealers n a fully disclsed basis r an mnibus basis Lcatins where thse custmers assets are kept fr example, U.S. depsitry, freign depsitry and issuer transfer agents Prtiviti 3

4 The prpsed Frm Custdy uses multiple questins and charts t request infrmatin in nine categries, as fllws: (1) Accunts Intrduced n a Fully Disclsed Basis These questins are designed s that the brker-dealer can infrm the regulatr whether the brker-dealer (a) intrduces its custmers t ther brker-dealers in whle r in part and n a fully disclsed basis, and (b) identifies the names f such carrying brker-dealers. (2) Accunts Intrduced n an Omnibus Basis Similar t (1) except that this item fcuses n mnibus accunts. (3) Carrying Brker-Dealers This item prvides infrmatin n whether the brker-dealer hlds custmer and nncustmer accunts n its wn bks and recrds. This item requires detailed infrmatin n where these accunts assets (cash and securities) are maintained and the frequency f recnciling the firm s recrds with the custdians recrds. This item requires infrmatin n the types and value f securities being held examples include U.S. and freign equities and U.S. and freign structured debt. On the cash side, infrmatin is required as t whether mney is swept t a mney market accunt r held in a reserve accunt. (4) Carrying fr Other Brker-Dealers This item disclses whether the brker-dealer acts as a clearing r carrying brker n behalf f ther brker-dealer firms. (5) Trade Cnfirmatins This item prvides infrmatin n the distributin f trade cnfirmatins t the brker-dealer s custmers. This will infrm the regulatr if the brkerdealer r a third-party service prvider fulfills the requirement. (6) Accunt Statements This item requests infrmatin n whether the brker-dealer r anther (clearing) brker-dealer sends accunt statements t the custmers. This will help the regulatr understand the brker-dealer s relatinships and target its examinatins. Fr example, the regulatr culd request custmer statements and custdial recrds and perfrm its wn recnciliatins. (7) Electrnic Access t Accunt Infrmatin This item prvides infrmatin n the custmer s ability t access accunt recrds electrnically. (8) Brker-Dealers Registered as Investment Advisers This item discusses the brkerdealer s applicability and capacity as a dually registered Brker-Dealer/Investment Adviser. (9) Brker-Dealers Affiliated with Investment-Advisers This item discusses whether the brker-dealer is affiliated with a separate Investment Adviser entity and in what capacity it is related t that entity. Summary In summary, this prpsal ffers three sets f amendments intended t strengthen the audits and reprting f brker-dealers t increase the fcus n their custdy activities and prtect custmer assets. In the cmmissin s press release, SEC Chairman Mary Schapir stated: When investrs hand their assets ver t a brker-dealer, they trust that their brker-dealer will hld and invest the assets as directed. T prtect investrs and help maintain cnfidence in the market, we must take strng steps t help safeguard the assets held by brker-dealers. Prtiviti 4

5 Abut Prtiviti Prtiviti (www.prtiviti.cm) is a glbal business cnsulting and internal audit firm cmpsed f experts specializing in risk, advisry and transactin services. The firm helps slve prblems in finance and transactins, peratins, technlgy, litigatin, gvernance, risk, and cmpliance. Prtiviti s highly trained, results-riented prfessinals prvide a unique perspective n a wide range f critical business issues fr clients in the Americas, Asia-Pacific, Eurpe and the Middle East. Prtiviti has mre than 60 lcatins wrldwide and is a whlly wned subsidiary f Rbert Half Internatinal Inc. (NYSE symbl: RHI). Funded in 1948, Rbert Half Internatinal is a member f the S&P 500 index. Cntacts Carl Beaumier Cry Gundersn Executive Vice President Managing Directr Glbal Leader Financial Services Practice U.S. Financial Services Practice Leader Prtiviti Inc. An Equal Opprtunity Emplyer. Prtiviti is nt licensed r registered as a public accunting firm and des nt issue pinins n financial statements r ffer attestatin services.

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