On episode 48 we discuss the upcoming SAA deadline for Registered Investment Advisers and Broker-Dealers.
CCO Buzz: Hello and welcome back! Can you believe it’s already June – where has the year gone? On episode 48 we are joined by a Senior Compliance Consultant. He’s here to discuss the upcoming SAA deadline for Registered Investment Advisers and Broker-Dealers. So with that, let’s get started…
Well we’re now into the second quarter of the year. What are some of the things CCOs should be thinking about?
Sr. Compliance Consultant: Well one of the regulatory items that is due in the 2nd quarter of the year is the annual SAA or Super Account Administrator Certification.
CCO Buzz: What is the “Super Account Administrator”?
Sr. Compliance Consultant: Each firm, whether you’re a Registered Investment Advisor or a Broker-Dealer, are required to have access to FINRA’s “Central Registration Depository” or “CRD” system. This the website maintained by FINRA where you upload forms like U4, U5, and Form ADV for Registered Investment Advisors. Each firm has one person who is in charge of being the administrator for the Firm’s CRD account. That person is called the Super Account Administrator, or “SAA.”
CCO Buzz: So, what is the annual SAA Certification?
Sr. Compliance Consultant: Each year, FINRA requires the SAA to log into the account and verify that the people who currently have log in credentials should STILL have those credentials and remove anyone who shouldn’t. The SAA will then check a box to certify the access is up to date.
CCO Buzz: When are firms required to do this certification?
Sr. Compliance Consultant: The window for performing the certification for 2019 is open right now. It started April 22nd and will close on June 21st.
CCO Buzz: Well, what happens if the SAA doesn’t perform the certification in time?
Sr. Compliance Consultant: Generally, the Firm’s access to the CRD system will be shut down.
CCO Buzz: What does the Firm’s SAA do to reestablish access?
Sr. Compliance Consultant: They’ll need to call FINRA’s Entitlement Department for further instructions on how to reestablish the access.
CCO Buzz: So, do happen to know what number they would need to call?
Sr. Compliance Consultant: Typically, you’d use FINRA’s helpline, which is (301) 590-6500, and you would select option one.
CCO Buzz: Ok, any last thoughts or tips on SAA Certification for our listeners?
Sr. Compliance Consultant: Yes, instructions on the entire certification process are available on FINRA’s website. Additionally, I think it is definitely a best practice to add this certification to your CCO calendar to try and prevent missing this certification when it comes due annually.
So if anybody has any questions or needs help with this annual certification, they can call us at Core Compliance & Legal Services, Inc. Our phone number is (619) 278-0020 and we’ll be glad to help you.
CCO Buzz: Well that’s it for this week’s episode. If you’d like additional information, please check out our website at www.corecls.com. You can also follow us on Facebook, LinkedIn or Twitter @CoreCLS. Thank you and we hope you tune into next week’s episode of the CCO Buzz.