Navigating The Rocky Shoals Of Rule 1017

Law360, New York (April 28, 2010, 12:36 PM EDT) -- Effecting a “material” change in a broker-dealer’s business, which, under certain circumstances, includes adding sales reps, can be an expensive, time-consuming and uncertain proposition. This is a result of the fact that in order to make such a material change, a broker-dealer must first file a Continuing Member Application (“CMA”) with FINRA under Rule 1017, and have that application approved before it can proceed.[1]

It can be challenging, however, even to determine whether or not a change is “material,” and, thus, whether a CMA is required....
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