I work in the home office of an independent b/d w/ series 7, 63, 24 licenses.  I recently learned that our HOME OFFICE registered agents staffing our equity trade desk, bond trade desk and compliance office functioning as principals are registered w/ only 1 state.  The functions these positions facilitate are as follows:

1.  Accept orders from properly state licensed independent registered reps, investment advisors, and money managers on behalf of their clients (located in all 50 states) via phone.

2.  Accept orders directly from clients living throughout the 50 states who are assigned a broker but are unable to reach their broker.

3.  Accept orders directly from clients living throughout the 50 states who's rep of record is our firm's home office (our firm's self directed house accounts) 

4.  signing off as broker on account forms for these house accounts described in #3.

5.  Signing off as principal for all new accounts and additional account addendums, both for clients w/ rep of record that is appropriately state licensed in the state of their clients' residence and house clients.

6.  Listed as supervisory principal and supervising branch offices in states that we aren't state licensed for as principal.

Our firm is state licensed as b/d in all states.  Our CFO is an accountant that appears to micro-manage and oversees all compliance issues.  To me it appears a conflict of interest may exist between saving on annual cost of state licensing necessary home office agents and regulatory compliance requirements.

I've been informed that b/c our firm is state licensed as a b/d in all states, we at the home office can accept client orders w/o being state licensed in any additional states from our own.  I've also been told that b/c our reps are appropriately licensed in states that their business is conducted, we at the home office may accept trades as clerks from the appropriately state licensed reps w/o ourselves needing to be state licensed.  I've been told that this rational extends to the signage of applications as both broker and principal as well as for acting as supervisory principal for our various state branch offices.

These explanations all seem like a load of crap to me.  I am not a lawyer.  I have read sec act of 1934 regarding b/d and agent registration requirements.  I have read various state registration requirement language.  I have read the USA, and nothing appears to directly exempt our activities in the home office from state registration. 

Are we transacting securities, supervising operations, and principally approving accounts in accord w/ federal and state law, or is our CFO attempting to save a buck?

Also, what repercussions exist if any both on a firm level and a registered agent level?

Any input would be greatly appreciated.  I feel I can't trust my firm's management and don't want to find myself acting outside of the law.

Shew