SEC DeskTop for FINRA Rules 3220, 3221 and 3222

The Financial Industry Regulatory Authority issued Regulatory Notice 16-29, for comments to proposed amendments to Rules 3220, 3221 and 3222. 17a-4’s SEC DeskTop has incorporated procedures to manage the proposed changes set forth in Notice 16-29.

FINRA Regulatory Notice 16-29 requested comment on proposed amendments to Gifts, Gratuities and Non-Cash Compensation including Rules 3220 (Gifts), 3221(Non-cash compensation) and 3222 (Business Entertainment). 17a-4, llc supports the proposed changes but recognizes that collecting, retaining and reviewing the information may become an administrative burden for many firms. In order to make the capture and review process as simple as possible, 17a-4 has developed its FINRA 3220 module of the SEC DeskTop.

SEC DeskTop for FINRA 3220:

  •     Allows employees to use a templated email to send in information on meals, gifts and seminars;
  •     Attaches documentation and receipts to the email;
  •     All information will be captured in a Microsoft SharePoint system that will alert compliance of a new expense;
  •     Upon receipt of email expense item, a workflow is started tracking the review and categorization of the expense through to approval;
  •     Information may be exported to Microsoft’s Excel to analyze and incorporate into compliance review reports.

The SEC DeskTop is a SharePoint platform which is fully SEC Rule 17a-4 compliant. All review comments and escalation information is captured as part of every expense item.


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