FINRA Reminds Firms to Submit their Annual Research Analyst Attestations pursuant to Amended Rule 2711
NASD Rule 2711 requires a senior officer of each FINRA member firm subject to NASD Rule 2711 to attest to FINRA by April 1 of each year that:
(i) The member has adopted and implemented written supervisory procedures reasonably designed to ensure that the member and its employees comply with the provisions of NASD Rule 2711; and
(ii) The member certifies that the committee responsible for reviewing and approving each research analyst's compensation has reviewed and approved each such research analyst's compensation and documented the basis upon which this compensation was established.
The NASD Rule 2711 Annual Attestation required to be filed by April 1 each year and may be submitted to FINRA in paper-based format, or alternatively, firms can file the attestation through an electronic, Internet-based receiving and processing system. The electronic filing system is available at http://www.finra.org/regnotes2711
Members (or persons designated by the member) with the ability to electronically file designated regulatory notices with FINRA by using the FINRA Entitlement System will have access to this new online form. Users who do not have a FINRA Entitlement account and need access to the new online form should see their Regulation Filing Account Administrator.
If your firm wishes to file the attestation in paper-based format, please submit it via facsimile to (866) 397-3290, or mail to the following address:
Attention: Research Analyst Attestation
Examination Programs, Member Regulation
1735 K Street, NW
Washington, DC 20006-1506
Please note that FINRA has provided Rule 2711 guidance to members in the following Notices to Members: 02-39, 02-44, "For Your Information November 2002", 03-44, 04-18, 04-25, 05-14, 05-24, and 05-34.