Disclosure Events and Customer Complaint Filings
Members are required to report to FINRA certain specified events, also known as "Ten Disclosure Events" pursuant to NASD Rule 3070(a) and NYSE Rule 351(a), as well as to report to FINRA statistical and summary information regarding customer complaints pursuant to NASD Rule 3070(c) and NYSE Rule 351(d). These reporting requirements are in addition to members' reporting requirements through Forms U4, U5, and BD filings, and help FINRA with the timely identification of matters of regulatory concern in line with our goal of enhancing risk based and focused approaches to regulation.
Members that are dually registered with the NYSE are exempt from NASD Rules 3070(a), (b) and (c) filing requirements if they file substantially similar reports pursuant to NYSE Rule 351, which FINRA has incorporated into its rulebook.
FINRA is working toward a new consolidated rulebook, which seeks to harmonize and streamline existing rules. To learn more about the process, read our Notices.
Pursuant to NASD Rule 3070(b), the Disclosure Events identified in NASD Rule 3070(a) must be reported within ten (10) business days after the member knows or should have known of their existence. Pursuant to NYSE Rule 351(b) the Disclosure Events identified in NYSE Rule 351(a) must be reported within thirty (30) calendar days after the member knows or should have known of their existence. The "Discovery Date" field for Disclosure Events is the date the member knows or should have known of the existence of the event.
The statistical and summary information regarding customer complaints required pursuant to NYSE 351(d) and NASD Rule 3070(c) is due quarterly by the 15th calendar day from the end of the quarter. If the 15th falls on a weekend or Holiday, the report is due the next business day following the 15th. For a current list of filing due dates, go to Member Firm Filing Due Dates.
Members must submit disclosure events and customer complaints electronically via the Regulatory Filings Application on the FINRA Firm Gateway which can be accessed directly through the web link https://RegFiling.FINRA.org. Any questions, concerns, or entitlement issues regarding form filing applications can be directed to (800) 321-6273.
Questions regarding the filing information can be directed to the appropriate District Office. Business and Technical questions can be directed to (800) 321-6273.
FINRA Notices
- 08-71 FINRA Requests Comment on Proposed Consolidated FINRA Rule Governing Reporting Requirements
- 08-64 Amendments to Incorporated NYSE Rules to Reduce Regulatory Duplication
- 08-47 Changes to Customer Complaint Reporting Procedures under NASD Rule 3070(c) and NYSE Rule 351(d)
- 08-40 Technology Changes for Reporting Certain Complaint and Disclosure Information
- 08-17 Reporting of Customer Complaints Relating to Auction Rate Securities
NASD Notices to Members
- 06-34 Technical Changes in the Reporting of Statistical and Summary Information Regarding Customer Complaints and Disclosure Events pursuant to NASD Rule 3070
- 03-23 SEC Approves Amendment to NASD Rule 3070 to Require Filing with NASD of Criminal and Civil Complaints and Arbitration Claims
- 02-34 SEC Approves Proposed Changes to NASD Rule 3070 Concerning the Reporting of Criminal Offenses by Members and Persons Associated with Members
- 96-85 Customer Complaint Reporting NASD Rule Update
- 95-81 SEC Approves Rules For Reporting Customer Complaint Information; Special NASD Notices to Members
Frequently Asked Questions
Q. Our firm was a defendant in a securities-related civil litigation that we settled for an amount that exceeds the threshold dollar amount in NASD Rule 3070(a)(7). For purposes of disclosing this event, is the "Discovery Date" the date we knew or should have known that we were a defendant in the case, or is it the date we knew or should have known of the settlement?
The "Discovery Date" is the date the firm knew or should have known of the settlement.
Q. What is the difference between the "edit filing" function and "amend filing" function?
"Edit filing" can be performed only when the filing is still in the "draft" mode. Once a filing is submitted and a member wants to make certain changes to it, the firm must use the "amend filing" function and re-submit that filing. The amended filing will be version number "2".
Q. What kind of information is expected to be placed in the "Comment" field (which is an optional field)?
Any additional information regarding a customer complaint or disclosure event that a member believes may be useful to the FINRA staff.
Q. What is the difference between the "Filing #" and the "Complaint #" fields?
"Filing #" is generated automatically by the system. "Complaint #" (or "Disclosure #") is a firm's own numbering system (if it has one) for tracking purposes.
Q. Where does a filing go if a member enters the information, closes the form, and fails to hit the "submit" button?
It will be stored in the "Draft" folder until submitted.
Q. Can a filing be submitted if any of the required fields are left blank?
No. The system will display an error message and not take a submission if any of the required fields are not entered
Q. What are the Disclosure Events and Complaints Problem and Product Codes?
View Problem and Product Codes (PDF 36 KB)
