Exam focus
FINRA Series 28 Introducing Broker-Dealer Financial and Operations Principal route.
Who this helps
- - Introducing broker-dealer founders
- - FinOp principal candidates
- - Fully disclosed brokerage teams
- - Compliance consultants mapping Series 27 versus Series 28
Route map
- 1. Start with the operating model: fully disclosed introducing broker-dealer, no customer account carrying, no custody of customer funds or securities, clearing firm relationship, net capital category, and books and records responsibility.
- 2. FINRA states Series 28 assesses FinOp principal competency for an introducing broker-dealer that does not carry customer accounts or hold customer funds or securities.
- 3. Series 28 is a principal-level exam, requires association with and sponsorship by a FINRA member or applicable SRO member firm, and FINRA states it does not have a corequisite exam.
- 4. Use the Series 27 versus Series 28 distinction when a firm changes clearing, custody, market making, municipal, or net capital assumptions.
Licensing context
- - Series 28 is an abbreviated FinOp route for qualifying introducing broker-dealer models, not a general operations, compliance, or supervisory-principal exam.
- - The firm still needs reliable financial reporting, books and records, net capital, customer protection analysis, funding controls, clearing-firm oversight, and regulatory filing discipline.
- - If the broker-dealer carries accounts, holds customer funds or securities, or meets a higher net capital category, Series 27 analysis may be required.
Study focus
- - Study financial reporting, operations, books and records, net capital, customer protection, funding, cash management, and how fully disclosed clearing affects the evidence file.
- - Build a clearing and custody assumption map explaining who holds accounts/assets, who sends confirmations/statements, who reconciles, and who owns regulatory reports.
- - Compare the Series 28 role to Series 27 FinOp and Series 24 supervisory principal responsibilities.
What to verify before relying on the route
- - Whether the firm truly does not carry customer accounts or hold customer funds or securities.
- - Whether the minimum net capital category and municipal securities facts push the firm toward Series 27.
- - Whether clearing arrangements, outsourcing, books and records, funding, and financial reporting owners are documented.
Application tie-in
- - For a FINRA NMA, connect Series 28 evidence to the clearing agreement, non-carrying model, net capital plan, books and records, financial reporting calendar, and vendor oversight.
- - Evidence should include FinOp role description, Form U4/CRD, procedures, reporting responsibilities, reconciliation controls, and backup coverage.
- - A change from introducing/fully disclosed to carrying or market making should trigger a fresh Series 27 versus Series 28 review.
Common mistakes
- - Using Series 28 without proving the firm is a qualifying introducing broker-dealer model.
- - Treating clearing firm outsourcing as removing the firm's own books, records, and financial responsibility controls.
- - Ignoring net capital category changes that can move the firm toward Series 27.
Paper and module study maps
- - Series 28 exam study map for introducing broker-dealer FinOp principals: FINRA Introducing Broker-Dealer Financial and Operations Principal Exam context.
Disclaimer
Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.