November 2015 Must-Dos
2016 Preliminary Renewal Statements and Review of Registrations
- Now is the time for every firm to review which FINRA, SRO and jurisdiction/state registrations it wishes to retain, add, or delete for the year 2016.
- Firms may now begin to submit post-dated Forms U5, BDW, ADV-W and BR Closing/Withdrawal via Web CRD (and/or IARD). All post-dated forms must be dated 12/31/2015 and submitted to FINRA no later than 11pm EST on November 13, 2015.
- On Monday November 16, all FINRA member firms will have the ability to view and print their Preliminary Renewal Statement from FINRA via WebCRD. The preliminary renewal statement amount is based on all existing firm, individual and jurisdiction registrations in place as of 11pm on November 13.
- By December 18, each firm must have sufficient funds, in full, in either its Flex-Funding or Renewal Account, to fund the fees for the firm’s and representatives’ registrations. Please view alternative funding methods in FINRA Regulatory Notice 15-40 (hyperlink below).
- Regardless of whatever registration changes each firm may contemplate or effect, the precise amount that appears on the Preliminary Renewal Statement must be available in either account or paid via alternate means by December 18.
- If payment is not received by December 18, firms will be assessed a Renewal Late Fee. Typically, the penalty is 10 percent of the firm’s final renewal assessment or $100, whichever is greater, with a cap of $5000.
- January 4, 2016, Final Renewal Statements will be available on CRD. Any over-payments or under-payments resulting from the year-end registration process will have been reconciled by FINRA and will appear as an amount due or a credit on the Final Renewal Statement.
- Please see FINRA Regulatory Notice 15-40 at http://www.finra.org/industry/notices/15-40 for further information or contact us for additional information.
Please contact us if you need help enhancing or implementing additional policies or controls, or if you need assistance with modifying your supervisory procedures or other year-end matters.