ARTICLE
6 January 2020

FINRA Provides Clarification On 2020 Member Firm Renewals

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FINRA provided clarification to member firms (e.g., broker-dealers, investment adviser firms, agents and investment adviser representatives
United States Finance and Banking

FINRA provided clarification to member firms (e.g., broker-dealers, investment adviser firms, agents and investment adviser representatives, and branches) on reviewing, adjusting and responding to their "Final Statements" (i.e., fee adjustments) and renewal reports.

As previously covered, FINRA notified firms that:

  • their Final Statements and renewal reports became available on January 2, 2020; and
  • payment of the full amounts in the Final Statements are due by January 17, 2020.

FINRA clarified that:

  • if the Final Statement amount is greater than that of the preliminary statement, additional renewal fees must be paid by January 17, 2020;

  • any overpayments will be credited to the firm's Flex-Funding Account;
  • any discrepancies in a firm's Final Statement should be submitted to FINRA by January 17, 2020; and
  • firms are expected to "carefully" review their annual reports, and are recommended to keep them in their permanent records.

    The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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