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FINRA’s Continued Response to COVID-19

March 25, 2020
Volume 12


  • Regulatory Notice
  • UPC Advisories

Upcoming Deadlines and Effective Dates
  • FINRA Requests for Comment

Education and Compliance Programs

FINRA announced that it has named Greg Ruppert as Executive Vice President, National Cause and Financial Crimes Detection Programs. Ruppert joined FINRA on March 23 and reports directly to Bari Havlik, Executive Vice President, Member Supervision.

In response to the coronavirus disease (COVID-19) situation, FINRA has canceled the Annual Conference. We apologize for any disappointment or inconvenience this necessary decision causes. Your wellbeing is paramount, and we are taking the necessary precautions to mitigate any health risks, and with your safety in mind.

Registrants will receive a cancellation email tomorrow morning and FINRA will issue a full refund for registration fees. FINRA has also canceled all hotel reservations that were made through the conference registration portal. If you have questions, please feel free to contact us at [email protected]


FINRA updates rules regarding level 3 market-wide circuit breaker resumptions. On March 18, 2020, in conjunction with other self-regulatory organizations, FINRA filed a proposed rule change to amend Rule 6121.02 (Market-wide Circuit Breakers in NMS Stocks) to establish a standardized approach for resuming trading in all NMS stocks following a Level 3 market-wide circuit breaker (MWCB) halt. Effective immediately, for any Level 3 MWCB, members may resume trading otherwise than on an exchange in any NMS stock on the trading day following the Level 3 MWCB, and would not need to wait for the primary listing market to re-open trading in a security, so long as the halt has been lifted by the applicable securities information processor (and where a separate regulatory halt is not also in effect for the security).

FINRA is committed to providing guidance, updates and other information to help stakeholders stay informed about the latest COVID-19 developments. This week, FINRA:

  • Provided an update on its Regulatory Operations.
  • Temporarily extended the time period for submitting fingerprint information under Rule 1010(d) in accordance with an SEC order providing a temporary exemption from the fingerprinting requirements of Securities Exchange Act Rule 17f-2.
  • Provided 17 new responses to member firms’ Frequently Asked Questions on various topics. Note that the temporary relief provided does not extend beyond the identified rules and requirements.
  • Compiled State "Shelter-in-Place" and "Stay-at-Home" Orders to aid member firms.
  • Provided updated guidance regarding enrollment window extensions for exam candidates and the temporary closure of Prometric test centers.
  • Extended the postponement of In-Person Arbitration & Mediation Hearings from May 1, 2020, to May 31, 2020.
  • Delayed the March 30, 2020, effective date for firms to begin submitting the last four digits of a customer’s Social Security or tax identification number and the update for certain validation identifiers and validation criteria to meet Regulation T calls, as outlined in Regulatory Notice 18-30. The new effective date will be May 31, 2020, and the testing cycle will continue to be available until May 15, 2020.
FINRA will continue to consider additional relief or adjustments as appropriate. For all of FINRA’s latest COVID-19 updates, visit FINRA’s website.

FINRA Amends the FINRA Corporate Financing Rule

FINRA has amended its Rule 5110 (Corporate Financing Rule - Underwriting Terms and Arrangements) to make substantive, organizational and terminology changes to the rule, outlined in Regulatory Notice 20-10. The amendments to Rule 5110 modernize, simplify and clarify its provisions while maintaining important protections for market participants, including issuers and investors participating in public offerings. The implementation date for amended Rule 5110(a)(3)(A), (a)(4)(A)(ii) and (a)(4)(A)(iii) was March 20, 2020. The implementation date for all other provisions in amended Rule 5110 is September 16, 2020.

UPC Advisories

The following UPC Advisories were published in the last week:

  • UPC #07-20: MabVax Therapeutics Holdings, Inc. (MBVXQ)
  • UPC #08-20: Zoom Technologies, Inc. (OTC: ZOOM), Zoom Telephonics, Inc. (OTC: ZMTP), and Zoom Video Communications, Inc. (Nasdaq: ZM)

 Upcoming Deadlines and Effective Dates

FINRA Requests for Comment

FINRA’s Capital Acquisition Broker (CAB) rules provide a simplified rulebook for broker-dealers that engage only in limited capital advisory, corporate restructuring and private placement activities. FINRA is requesting comment on proposed amendments to the CAB rules, as described in Regulatory Notice 20-04, to make them more useful to CABs without reducing investor protection. The comment period has been extended to May 15, 2020.

FINRA is requesting comment on a proposal to implement the recommendations of the CE Council regarding enhancements to the continuing education requirements for securities industry professionals. The proposal, described in Regulatory Notice 20-05, would change the: (1) Regulatory Element to provide annual training, make the content more relevant, incorporate diverse instructional formats, publicize the learning topics in advance and enhance the related management systems; (2) Firm Element to expressly recognize other training requirements, improve the guidance and resources available to firms and establish a content catalog; and (3) Continuing Education Program to enable individuals who terminate their registrations the option of maintaining their qualification by completing continuing education. The comment period has been extended to May 31, 2020.

 Education and Compliance Programs

The recording of the recent Small Firm Conference Call is now available for FINRA members. On the call, Robert Cook and Senior Vice President of Member Relations and Education Chip Jones were joined by FINRA senior leaders to discuss updates and implications of COVID-19.

Registration is open for the 2020 Small Firm Conference. The event will be held on November 11–12 in Santa Monica, California, and will bring together FINRA staff and industry peers for in-depth discussions on small firms' practices. Register early to receive discounted registration rates!

Save the Date for these upcoming FINRA events:

  • FINRA Institute at Georgetown Certified Regulatory and Compliance Professional® Program – Week I | July 19–24, 2020 | Washington, DC
  • FINRA Institute at Georgetown Certified Regulatory and Compliance Professional® Program – Week II | November 15–20, 2020 | Washington, DC

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