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Forums > Broker Dealer Branch Office Examinations > non-registered branches
 
 


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Wesley Bean
    06/17/08 at 03:12 PMReply with quote#1

Any suggestions on how to monitor a criteria like a location being used for 30 days or less each year as to whether that office needs to be registered?  How do you ensure that the location truly is being used for less than 30 days?
ACA
    06/23/08 at 10:11 AMReply with quote#2

Monitoring (if a location is utilized more than 30 days) is one of the more challenging areas of branch office supervision to enforce.  There is no one situation or method of monitoring that fits all types of firms with various branch office populations (sizes).  That being said, I recommend having all RR’s that utilize the particular location to email compliance each type they are on-site utilizing the office location.  Compliance can monitor the branch frequency of use from the main office.  To enforce or monitor this requirement the firm can review the RR’s email activity on a monthly basis to identify situations where the office location maybe utilized more frequently then compliance has been advised.  If the RR’s do not have email capabilities then the firm could use some type of “Branch Office Log”, where each RR using the location must sign, date, and note the duration and the purpose of their on-site office use.  This document can be forwarded to compliance on a monthly basis for analyzing.

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