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We could also consider the underlying preparations with foreign custodians to determine should they permit cross-liens or use temporary holding accounts. Where by purchaser securities could be held in, or go as a result of, short-term holding accounts, We'll contemplate irrespective of whether these accounts are very good Manage areas and whether or not firms have instituted affordable strategies to watch them for consumer securities.
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Corporations need to be attentive for their brokers’ activity in microcap stocks, specifically when brokers clearly show a brand new or sudden curiosity in obtaining microcap stocks for their very own accounts or Individuals of their consumers. FINRA will examine brokers who use their unique or their customers’ accounts to coordinate investing in microcap stocks with known or unidentified counterparties.
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FINRA will evaluate companies’ BCPs with a spotlight on their own implementation on the program. For example, we will evaluation how and below what situation firms activate their BCPs, how they classify devices as mission-vital or secondary, how they achieve details backup and Restoration, and the place relevant, how companies coordinate with their affiliate marketers and distributors for the duration of a company continuity situation. We may also critique corporations’ plans for restoring systems, processes and records as soon as They may be ready to return to typical business, along with how they make Individuals choices.