Regulatory Notice 15-42

FINRA to Require Electronic Submission of Subordination Approval Requests

Effective Date: November 30, 2015

Executive Summary

FINRA is launching, effective November 30, 2015, a new electronic platform on Firm Gateway for firms to submit all new requests for approval of proposed subordinated loan agreements and secured demand note agreements (referred to as subordinations), including renewals of existing agreements. This Notice discusses the electronic submission process, which will replace the current submission of subordination requests in hard copy form to FINRA. As of November 30, 2015, all new requests must be submitted in electronic form through Firm Gateway, and FINRA will no longer accept new requests filed in hard copy form.

Questions concerning this Notice should be directed to:

  • Sheryl Martinez, Examination Manager, Membership Application Program (MAP), at (212) 858-4135; or
  • Diana Hernandez, Regulatory Specialist, MAP, at (646) 315-8476.