SDDco Perspective Newsletter

The SEC Provides COVID Relief Surrounding Annual Audited Financial Statements & Other Filings

Robert Fortino
Managing Partner

Bob Fortino

The SEC’s Division of Trading and Markets issued guidance to member firms required to file certain reports in paper format. This guidance also extends to electronic submissions using EDGAR and FINRA’s WEB CRD system. The guidance addresses the impracticality of having these submissions signed and notarized during the COVID-19 pandemic. The SEC allows for relief from those requirements indefinitely, until such time as notice is given that the relief will be terminated. The original notification (click here to view) was issued in the early part of 2020 and the SEC recently re-affirmed that it still applies.

Specifically, the notice will not recommend enforcement action if the member firm does not comply with the paper format submission requirements or manual signature requirements if:

  • the filers contact the division to discuss how to file electronically in lieu of paper format.
  • the Impacted Paper Submissions are signed electronically, if a signature is required, by using a typed form of signature within the electronic submission that will take the position of the manual signature.
  • a signatory of any Impacted Paper Submission retains a manually signed signature page or other document authenticating, acknowledging, or otherwise adopting his or her signature that appears in typed form within the electronic submission and provides such document, as promptly as practicable, upon request by Division or other Commission staff;
  • such document indicates the date and time when the signature was executed; and
  • the filer or submitter establishes and maintains policies and procedures governing this process.

The disallowance of what would normally be deductible expenses, effectively makes the PPP loan proceeds taxable. The IRS did not address what a taxpayer should do if they disallow the expenses, but are subsequently denied forgiveness in the following tax year.

Questions and notifications should be directed to the Division staff at

Questions? Or have an article recommendation? Let's connect!


Forward to Friend

SDDCO RIA Registration & Compliance
Speak with our RIA Registration and Compliance Specialists

We will support your firm’s ongoing compliance with the Investment Advisers Act and associated state requirements including:

  • Administering your IARD profile and all ADV amendments
  • Maintaining and updating your Compliance Manual
  • Reviewing all marketing and performance materials
  • Developing Solicitors Agreements and Disclosure Statements
  • Conducting Annual Reviews
  • Guiding you during regulatory exams
  • Drafting responses to regulators


Broker-Dealer Membership and Compliance

The SDDco Group, through its subsidiary, SDDco Regulatory Services provides full-service compliance consulting to both new and established broker-dealers (BDs) and Investment Advisers (IAs). This month, we are highlighting our broker-dealer practice.

What Services Do We Provide To BDs?

Our team of experienced consultants assist BDs seeking:

  • Ongoing regulatory compliance advice and support
  • CRD Registration Services
  • A qualified Series 24 registered consultant to serve as the designated Chief Compliance Officer (CCO) or other Principal roles
  • FINRA New or Continuing Membership Applications, Materiality Consultations, and Membership Agreement Changes

Why Should You Hire an SDDco Compliance Consultant for Ongoing Compliance Support?

We are experienced in providing ongoing support to broker-dealers of many stripes and sizes and our services are highly specialized. Our consulting team understands the business implications of complying with industry rules. We use that lens to determine the best advice for our client partners on how to remain compliant. SDDco-RS offers a suite of compliance services on a retainer or project basis which always encourages frequent communication with our clients.

Why Should You Hire an SDDco Compliance Consultant for FINRA Membership Applications?

FINRA New Membership Application (NMA) requirements are extensive and exacting. SDDco Regulatory Services shepherds the entire process. Success hinges on understanding the client’s business, developing a clear and consistent presentation to the regulator and formulating appropriate responses to FINRA information requests. Our consultants are skilled and uniquely experienced in this meticulous process, having represented hundreds of firms of varying size and structure. SDDco-RS also assists with the FINRA Continuing Member Application (CMA) process as it relates to changes in your current business.

Learn More by Downloading Our Broker-Dealer Membership & Compliance Services Brochure

Accounting Services Brochure

SDDco Group makes this general information available for educational purposes only, the contents of which were not originated from SDDco. SDDco is not affiliated with any of the publishing persons or entities of the articles herein. The information provided should not be construed as legal advice. This email may constitute an advertisement under U.S. law. | | (212) 751.4422