Library
Indexed sources, authorities, and document versions.
Advisers Act Rule 204A-1 — Investment Adviser Codes of Ethics
Rule 204A-1 was adopted in 2004 (compliance date 2005) under § 204A of the Advisers Act. It requires every SEC-registered investment adviser to adopt a code of ethics that, at a mi…
Advisers Act Rule 206(4)-1 — Marketing Rule
The Marketing Rule, adopted in December 2020 with a compliance date of November 4, 2022, replaced the Commission's prior advertising rule (former Rule 206(4)-1) and also rescinded…
Advisers Act Rule 206(4)-2 — Custody Rule
Rule 206(4)-2 applies to every investment adviser registered or required to be registered under the Act that has custody of client funds or securities. The Commission proposed comp…
Broker-Dealer BSA/AML Program — 31 CFR Part 1023 (Customer Identification Program, SAR, Recordkeeping)
Part 1023 of 31 CFR is the FinCEN rulebook applicable to brokers or dealers in securities (as defined in Section 3(a)(4) and (a)(5) of the Exchange Act). It implements the Bank Sec…
FINRA 2025 Routine Examination — Exit Letter (Kestrel Securities)
**To:** CEO, Kestrel Securities, LLC **From:** Examiner in Charge, FINRA Department of Member Supervision, New York Regional Office **Date:** March 28, 2025 **Exam No.:** (internal…
FINRA Letter of Acceptance, Waiver and Consent (AWC) — Best Execution Failures (Hypothetical Matter Representative of Public Disciplinary Actions)
**In the Matter of:** - FIRM RESPONDENT (CRD No. REDACTED) ("the Firm"), a FINRA-member broker-dealer; and - REGISTERED PRINCIPAL (CRD No. REDACTED), Chief Executive Officer. > Thi…
FINRA Rule 3110 — Supervision
Each member shall establish and maintain a system to supervise the activities of each associated person that is reasonably designed to achieve compliance with applicable securities…
FINRA Rule 3130 — Annual Certification of Compliance and Supervisory Processes
Each member shall designate and specifically identify on Schedule A of Form BD one or more principals to serve as a chief compliance officer (CCO). Each member shall have its chief…
FINRA Rule 5310 — Best Execution and Interpositioning
In any transaction for or with a customer or a customer of another broker-dealer, a member and persons associated with a member shall use reasonable diligence to ascertain the best…
Investment Advisers Act Section 206 — Antifraud Provisions
Section 206 (15 U.S.C. § 80b-6) is the antifraud cornerstone of the Investment Advisers Act. It applies to every investment adviser, whether or not registered, and codifies the fed…
Kestrel Advisors — Marketing Rule Review and Advertisement-Approval Procedures
**Owner:** Kestrel Advisors CCO **Applies to:** All personnel of Kestrel Advisors, LLC, and any third party acting as a solicitor, endorser, or marketer for Kestrel Advisors. This…
Kestrel AML Program — Anti-Money Laundering and Counter-Financing of Terrorism
**AML Compliance Officer (AMLCO):** [Registered Principal — on file with FINRA via Form BD Schedule A] **Approved by:** Board of Directors, September 24, 2025. **Annual independent…
Kestrel Best Execution Committee — Q1 2026 Meeting Minutes
**Date:** Thursday, March 5, 2026, 10:00–12:30 ET **Location:** New York HQ, 42nd-floor conference room (with remote video for the Independent Quantitative Reviewer) **Meeting type…
Kestrel Best Execution Policy
**Owner:** Best Execution Committee **Approver:** Chief Compliance Officer **Annual review:** Required; next review September 2026. This Policy establishes Kestrel Securities' fram…
Kestrel Code of Ethics and Personal Trading Policy
**Applies to:** All directors, officers, and employees of Kestrel Securities, LLC and Kestrel Advisors, LLC, and any consultant or contractor designated as a "supervised person" by…
Kestrel Information Barriers, Restricted List, and Watch List Policy
**Owner:** General Counsel **Approver:** Chief Compliance Officer **Review cadence:** Annual. This Policy establishes the information barriers ("ethical walls") that separate Kestr…
Kestrel Market Access Controls — 17 CFR 240.15c3-5
**Owner:** Chief Risk Officer (CRO), jointly with CCO **Annual CEO certification:** Required under 17 CFR 240.15c3-5(d); executed each February for the preceding calendar year. Kes…
Kestrel Reg BI Disclosure and Recommendation-Handling Procedures
**Owner:** Retail Compliance **Approver:** CCO **Applies to:** All registered representatives of Kestrel Securities who make recommendations to retail customers, and their supervis…
Kestrel Reg SHO Locate Policy and Fail-to-Deliver Close-Out Procedures
**Owner:** Operations — Stock Loan Desk, with Compliance oversight **Applies to:** Equities Trading Desk, Stock Loan Desk, Operations, and Compliance. This Policy implements Kestre…
Kestrel Securities — FINRA Rule 3130 CEO Annual Certification (2025)
**Certifying officer:** Chief Executive Officer, Kestrel Securities, LLC **Date executed:** February 20, 2026 **Scope of certification:** Calendar year ended December 31, 2025 ---…
Kestrel Securities — Written Supervisory Procedures: Equities Trading Desk
**Document owner:** Head of Compliance **Approver:** Chief Compliance Officer (CCO) **Annual review:** Required under FINRA Rule 3130; next review July 2026. **Distribution:** All…
Kestrel Trade Error Correction Policy
**Owner:** Head of Operations **Approver:** Chief Financial Officer and Chief Compliance Officer **Applies to:** All Kestrel Securities and Kestrel Advisors personnel whose activit…
Kestrel Trade Surveillance — Q4 2025 Alert Summary
**Reporting period:** October 1, 2025 – December 31, 2025 **Prepared by:** Compliance Surveillance Team (Equities Desk Compliance Officer + two analysts) **Reviewed by:** Chief Com…
Proposed SEC Regulation Best Execution — Proposed Rules 1100, 1101, and 1102 (Dec. 2022 proposing release)
**Status: PROPOSED — not currently in effect.** Release No. 34-96496 (December 14, 2022) proposes a new best-execution framework applicable to broker-dealers. The proposed framewor…
Reg SHO Rule 200 — Definition of Short Sale and Order Marking
Regulation SHO governs short sales of equity securities. It establishes: 1. Definitions used throughout the short-sale regulatory framework (Rule 200); 2. Order-marking requirement…
Reg SHO Rule 201 — Price-Test Restriction (Alternative Uptick Rule)
Rule 201 imposes a short-sale price-test restriction on a "covered security" (any NMS stock) that has experienced a decline in price of 10% or more intraday relative to the prior d…
Reg SHO Rule 203 — Borrowing and Delivery Requirements (Locate Requirement)
If a broker-dealer knows or has reasonable grounds to believe that the sale of an equity security will be executed pursuant to an order marked "long," the broker-dealer shall make…
Reg SHO Rule 204 — Close-Out Requirement for Fail-to-Deliver Positions
A participant of a registered clearing agency must deliver to the registered clearing agency, for clearance and settlement on a long or short sale in any equity security, by settle…
Regulation Best Interest and Form CRS — 17 CFR 240.15l-1 and 17 CFR 240.17a-14
Regulation Best Interest establishes a standard of conduct for broker-dealers and their associated persons when making a recommendation of any securities transaction or investment…
Regulation NMS Rule 605 — Market Center Disclosure of Order Execution Information
Rules 605 and 606 are the principal public-disclosure provisions of Regulation NMS governing order routing and execution quality. Rule 605 applies to market centers and requires th…
Regulation NMS Rule 606 — Broker Disclosure of Order Routing Information
Every broker or dealer shall make publicly available for each calendar quarter a report on the routing of non-directed orders in NMS stocks that are submitted on a held basis, and…
SEC Rule 15c3-1 — Net Capital Rule
Rule 15c3-1 is the SEC's principal financial-responsibility rule for broker-dealers. It requires every broker or dealer to maintain at all times "net capital" no less than a specif…
SEC Rule 15c3-3 — Customer Protection Rule (Reserves and Custody of Securities)
Rule 15c3-3 protects customer funds and securities held by a broker-dealer by requiring (i) segregation of fully-paid and excess-margin securities in a "control" location and (ii)…
SEC Rule 15c3-3a — Customer Reserve Formula
The Customer Reserve Formula is a computation, performed in accordance with the formula set forth in § 240.15c3-3a, of the "net credit balance" a broker-dealer must hold in the Spe…
SEC Rule 15c3-5 — Market Access Rule (Risk Management Controls)
Rule 15c3-5 — the "Market Access Rule" — requires every broker-dealer with market access to an exchange or ATS, and every broker-dealer that provides market access to a customer or…
SEC Rule 17a-3 — Records to be Made by Brokers and Dealers
Rule 17a-3 requires every registered broker-dealer to make and keep current a specified set of records. The records enumerated in paragraph (a) are the principal day-to-day operati…
SEC Rule 17a-4 — Records to be Preserved by Brokers and Dealers
Rule 17a-4 sets forth the retention periods and preservation conditions for the records enumerated in Rule 17a-3 and for other records of the broker-dealer's business. The followin…