SEC / FINRA / state securities regulators

Series 28 exam study map for introducing broker-dealer FinOp principals

How Series 28 study fits introducing broker-dealer FinOp responsibility for firms that do not carry customer accounts or hold customer funds or securities.

Exam focus

FINRA Introducing Broker-Dealer Financial and Operations Principal Exam context.

Who this helps

  • - Introducing broker-dealer FinOp candidates
  • - Fully disclosed brokerage founders
  • - Compliance consultants
  • - Broker-dealer finance teams

Why this matters

  • - 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.
  • - The Series 28 route still includes financial reporting, operations, books and records, net capital, customer protection, funding, cash management, and regulations.
  • - Series 27 should be reconsidered if the firm carries accounts, holds customer funds or securities, makes markets, or changes net capital assumptions.

Study map

Introducing model

  • - Study how a fully disclosed clearing arrangement changes account, confirmation, statement, custody, reconciliation, and financial reporting evidence.
  • - Document why the firm does not carry customer accounts or hold customer funds or securities, and how the clearing firm relationship is controlled.

FinOp controls

  • - Study net capital, customer protection analysis, books and records, funding, cash management, FOCUS reporting, notices, and escalation responsibilities.
  • - Keep Form U4, sponsorship, role description, reporting calendar, vendor/clearing oversight, backup coverage, and register-review evidence together.

Licensing tie-in

  • - Series 28 can support the FinOp principal evidence file for a qualifying introducing broker-dealer; it does not remove the firm's own financial responsibility obligations.
  • - A FINRA NMA should show clearing agreement assumptions, non-carrying model facts, net capital plan, books and records, reporting owners, and oversight procedures.
  • - A model change toward carrying, custody, market making, municipal activity, or higher net capital should trigger a Series 27 versus Series 28 review.

Booking and sponsorship

  • - Use FINRA's Series 28 page to confirm current outline, no-corequisite status, and sponsorship requirements.
  • - Compare Series 28 with Series 27 before treating an introducing model as settled.
  • - Keep exam evidence with the clearing model, procedures, NMA evidence, and public register review.

Verify before studying

  • - Whether the firm truly does not carry customer accounts or hold customer funds or securities.
  • - Whether the net capital category, municipal securities facts, market making, or custody facts point toward Series 27.
  • - Whether clearing firm oversight, books and records, reconciliations, reporting calendar, and backup coverage are documented.

Common mistakes

  • - Using Series 28 as a shortcut without proving the introducing broker-dealer model.
  • - Assuming a clearing firm eliminates the broker-dealer's books, records, net capital, and customer protection evidence.
  • - Missing a Series 27 trigger when the business model expands.

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.