Formation & Registration
Build the operating model before the application describes it.
Applications are strongest when the business plan, supervisory structure, people, vendors, workflows, financial responsibilities and books-and-records model agree with one another. We help organize that work before, during and after the filing process.
FINRA New Member Application (NMA)
Support for the formation and membership process may include:
- Business-model evaluation and operating-plan development
- Ownership, control and organizational documentation
- Supervisory structure, licensing strategy and responsibility matrices
- Written Supervisory Procedures and AML-program coordination
- Clearing, custody, communications, books-and-records and vendor workstreams
- FINRA Membership Application Program coordination, information requests, interviews and launch readiness
RIA Registration & Regulatory Filings
Registration work may include:
- SEC or state investment-adviser registration coordination
- Form ADV, Form BD, Form U4/U5 and related filing workstreams
- State registrations, notice filings, branches and IAR coordination
- Policies, disclosures, agreements, compliance calendars and implementation evidence
- Responses to regulator questions and remediation of filing gaps
Continuing Membership & Material Change
A change on paper can reshape the whole control environment.
We help firms assess, coordinate and implement changes that may require a Continuing Membership Application (CMA), other regulatory filings, or broader updates to supervision, capital, governance, technology and records.
FINRA Continuing Membership Application (CMA)
Depending on the proposed change, work may include:
- Ownership or control changes and affiliate restructurings
- New business lines, products, customer types or compensation models
- Changes to clearing, carrying, custody or material vendor relationships
- Material changes to financial, operational or supervisory arrangements
- Change-impact analysis, application coordination, supporting evidence and readiness
Expansion & Structural Change
Other business-change support may include:
- New branches, OSJs and additional state registrations
- New registered persons, supervisors or shared-service arrangements
- Promoter, solicitor, referral, affiliate or partnership structures
- New technology, communications, cybersecurity and books-and-records solutions
- WSP, AML, governance, vendor and compliance-calendar updates
Implementation & Evidence
Regulatory filing is only one workstream.
We coordinate the people, decisions, dependencies, procedures, vendors, deadlines and evidence required to move from proposal to controlled operation. Legal and regulatory determinations remain with the firm, its counsel and the applicable regulator.
Scope→Regulatory Path→Owners→Controls→Implementation→Evidence