December Dates

These kinds of dates are not the fun ones, but they're worth paying attention to:

1. December 10: Due date for notification of change of accountant. If you have appointed a different accountant to do your annual audit, you have to tell SEC and FINRA about it. Please reference my blog entry of last December for specifics--the information is still good and you'll save me time. You're great: thanks!

2. December 13: FINRA renewal payments due. Remember, even if you disagree with what is on your preliminary renewal statement, pay it! You can make amendment filings now that will be reflected on the final statement (Jan. 3): at that point you can get a refund if you overpaid. Here is a link to FINRA's page on payment options.

3. December 15: Effective date of new Rule 3270 requiring reps to pre-notify the firm of their new outside business activities--and requiring the firm to consider those activities in the context of its securities business. I blabbed about this in a recent (yeah, October was recent in my mind) entry. See here.

4. December 23: Deadline for all year-end filings on CRD. Remember, you can post-mark termination filings (like dropping states or dropping reps) to December 31 if you want.

5. December 31: End of your right to use self-congratulatory Privacy Notices. The use of SEC's "model form" is advisable for those who want to be sheltered by the safe harbor. Not sure what I'm talking about? Search my blog for "Privacy Notices" and you'll hear all about it. 

6. December 31: The last day of the year. Oh, and as of the next day, in theory, the FACT ACT is enforceable. Since that effective date changes more often than I do when getting ready for a holiday party, I'm not convinced it will stick. See this blog for details and sarcasm.

Happy December, everyone!