HomeNews & ViewsComplianceCapital Forensics, Inc. and Eversheds Sutherland Release In-Depth Report on FINRA’s Regulatory Notice 19-04 Regarding 529 Plan Self-Reporting Initiative

Capital Forensics, Inc. and Eversheds Sutherland Release In-Depth Report on FINRA’s Regulatory Notice 19-04 Regarding 529 Plan Self-Reporting Initiative

  • February 21, 2019
  • Posted by: giawatkins
  • Categories: Compliance, FINRA
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Many Broker-Dealers Still Unaware of Extent of the Information Required by FINRA; The CFI/ES 529 Report Outlines Steps for Firms, With Self-Reporting Deadline Looming

PALATINE, Ill. and WASHINGTON, Feb. 21, 2019 /PRNewswire/ — Capital Forensics, Inc. (CFI) and Eversheds Sutherland (ES) announced today the publication of their in-depth Report that provides a detailed analysis of FINRA’s recently issued Regulatory Notice 19-04, regarding its 529 Plan Self-Reporting Initiative. The CFI/ES 529 Plan Report provides specific guidance for broker-dealers on what steps those firms must take to comply with the extensive amount of information required by FINRA within the next three months. The CFI/ES Report also reflects additional insights provided in FINRA’s February 20th member conference call.

Founded in 1993, Capital Forensics, Inc. (CFI) provides data analysis, expert testimony, litigation support and regulatory consulting for the financial services industry. CFI’s clients range from financial institutions – including broker-dealers, hedge funds and Registered Investment Advisers – to FORTUNE 500 companies.
Founded in 1993, Capital Forensics, Inc. (CFI) provides data analysis, expert testimony, litigation support and regulatory consulting for the financial services industry. CFI’s clients range from financial institutions – including broker-dealers, hedge funds and Registered Investment Advisers – to FORTUNE 500 companies.

The CFI/ES 529 Plan Report was researched and written by two of CFI’s Managing Directors – Kamran Fotouhi, CFA, a former FINRA Surveillance Director; and John Ivan, former head of compliance at a number of well-known securities firms – together with attorney Brian Rubin, the former Deputy Chief Counsel, Enforcement for NASD (now FINRA), who currently serves as the head of the SEC, FINRA and State Securities Enforcement Team in the Washington D.C. office of Eversheds Sutherland.

According to co-author, John Ivan, “Our intention in creating this in-depth 529 Plan Report is based on our desire to provide broker-dealers with a more thorough understanding of how they can address FINRA’s requirements. Despite the volume of information that’s been produced by various sources since the regulatory notice was published on January 28, there are still many firms that do not appreciate the vast amount of information they must obtain and analyze in advance of the FINRA’s April 1 and May 3 deadlines. There does not appear to be the sense of urgency this situation requires, given that FINRA will be expecting firms to ultimately have analyzed 529 Plan activity far greater than the five-year reporting period.” The restitution period may begin as early as 2008.

The CFI/ES 529 Plan Report is available to any broker-dealer, without charge or obligation, upon request. To receive a complimentary copy of the Report, interested parties should email CFI Managing Director, Eric Siber, at eric.siber@capitalforensics.com or call him at 847-392-0900. A prior version of the CFI/ES 529 Report was submitted for future publication in National Society of Compliance Professionals Currents.