I've noticed that some small boutiques that are FINRA members do not have Analysts/Associates with a Series 79 or 63, aren't these required to work in IB after a year or so? If anyone could shed some light on this I'd appreciate it.
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I've seen it at a decent amount of boutiques, but they were all M&A focused. You are right in that it is required, but my understanding is that its more strictly enforced for firms that issue securities (e.g. IPOs, or equity-related items, and whatnot).
My firm, along with other boutiques that I know of, that operate a bit looser, only focus on M&A. The way its been explained to me, as to how its somewhat justifiable that Analyst/Associates not be licensed within the 90 day mark, is that the boutiques tend to set up their deals as an asset sale, as oppose to a stock deal. If its stock deal then you're technically selling securities, and therefore need to be licensed. But if its an asset deal, then its not a security, and it falls in this gray area, which is not in direct violation with FINRA. With that said, its still a fuzzy line - its not a blatant in violation, and its somewhat defensible, but is still tricky.
That's how its been explained to me, and I'm sure there are more considerations that I'm missing.
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