Carrying Agreements
Chapters in this video
- 0:00 The introducing and carrying firm split
- 1:24 Written agreement and FINRA advance review trap
- 2:05 Fully disclosed versus omnibus clearing structures
- 2:40 Allocation of functions and the negotiable list
- 3:15 Safeguarding: the non-negotiable carrying firm duty
- 4:35 Customer disclosure timing and the annual reaffirmation trap
- 5:48 Due diligence and the 10 business day notice requirement
- 7:43 Rapid-fire exam recap
What this video covers
- Why a carrying agreement must be written and submitted to the Financial Industry Regulatory Authority (FINRA) in advance, and why starting to use it before FINRA review is a hard violation
- The difference between fully disclosed clearing (customer's name on the account at the carrying firm) and omnibus clearing (introducing firm's name on a single account), including where each structure is typically used
- How functions like account opening, margin compliance, recordkeeping, confirmations, order acceptance, and execution can be allocated between the two firms
- Why safeguarding of funds and securities must be allocated to the carrying firm and cannot be flipped to the introducing firm, and the customer-protection possession-or-control logic behind that rule
- When the customer disclosure document must be delivered (at account opening) and the specific triggers for a subsequent notice (change of parties or material change of allocation), with no annual reaffirmation requirement
- The due diligence the carrying firm must perform on the introducing firm and the 10 business day advance notice to FINRA before onboarding a new introducing firm's accounts
- Why the 10 business day notice is a hard operational gate that cannot be bypassed or accelerated, even if the agreement itself has already been accepted
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