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Upcoming Committee Elections

September 22 2021
Volume 38


  • Regulatory Notice
  • New FAQ
  • UPC Advisories

Upcoming Deadlines and Effective Dates
  • FINRA Elections
  • FINRA Requests for Comment

Education and Compliance Programs

In light of the challenges posed by the COVID-19 pandemic,
FINRA Rule 3110.17, which provides firms the option to satisfy their Rule 3110(c) obligations remotely, has been amended to include calendar year 2022 inspections obligations through June 30, 2022. Rule 3110.17, as amended, becomes operative on January 1, 2022, and does not extend to a member's inspection requirements beyond June 30, 2022.


Reminder: cybersecurity vulnerability in Apple products. FINRA reminds members that Apple released a security update last week to address a significant cybersecurity vulnerability in its products, including iPhones and iPads. The vulnerability provides a means for a hacker to take control of Apple devices without any action by the user. Given that many individuals use Apple products as their multi-factor authentication device, FINRA wants to ensure that members are aware of this vulnerability and are taking appropriate precautions. Please follow any related guidance provided by your organization, or available from Apple, to ensure that your Apple devices are fully patched and effectively secured.

Time is running out to add your name to the ballot for the upcoming Small Firm Advisory Committee and Regional Committee elections! Committee members play an important role by helping inform FINRA’s regulatory programs. See the Election Notices below for eligibility information and instructions on how to submit a candidate profile form by October 1.

Tune in to the latest episode of the FINRA Unscripted podcast. On this episode, we are joined by two of Member Supervision’s Single Points of Accountability to learn more about their roles, how they interface with member firms, and how their positions have evolved since the Member Supervision transformation took effect in 2020. Listen to the podcast.


FINRA Adopts Amendments to Rule 6432 Regarding Compliance With the Information Requirements of SEC Rule 15c2-11

FINRA has adopted amendments to Rule 6432 in light of the SEC’s amendments to SEC Rule 15c2-11. As amended, Rule 6432 will require a qualified inter-dealer quotation system to submit a modified Form 211 filing to FINRA in connection with each initial information review, and a daily security file to FINRA containing summary information for all securities quoted on its system on each day that it makes a publicly available determination permitted under SEC Rule 15c2-11, among other amendments. The amendments to Rule 6432, as outlined in Regulatory Notice 21-33, will take effect on September 28, 2021—in line with the compliance date for the amendments to SEC Rule 15c2-11.


FINRA has published new Frequently Asked Questions related to amended filing requirements of Rules 5122 and 5123 for retail communications regarding private placements. The new filing requirements, announced in Regulatory Notice 21-26, become effective on October 1, 2021.

UPC Advisories

The following UPC Advisories were published in the last week:

  • UPC #98-21: Vornado Realty Trust (VNOOP)
  • UPC #99-21: Western Alliance Bancorporation (WALPL)
  • UPC #100-21: Inpoint Commercial Real Estate (IPCRP)

 Upcoming Deadlines and Effective Dates

FINRA Elections

Election Notice 9/1/2021 notifies member firms of the upcoming nomination and election process to fill vacancies on FINRA’s Regional Committees. The Regional Committees play an important part of informing FINRA’s regulatory programs by, among other things, alerting FINRA to industry trends that could present regulatory concerns, and consulting with FINRA on proposed policies and rule changes. In this election, Regional Committees for the South and West regions each have six full-term vacancies, and the Midwest, North and New York regions each have four full-term vacancies to fill. Eligible candidates will be included on the appropriate ballot if they submit a candidate profile form to FINRA’s Corporate Secretary by Friday, October 1, 2021.

Election Notice 9/1/2021 informs small FINRA member firms of the upcoming Small Firm Advisory Committee (SFAC) election. Two seats on the SFAC are up for election, one representing the North region and one representing the West region. The SFAC provides guidance to FINRA staff, particularly regarding the potential impact of proposed regulatory initiatives on FINRA’s small firm members. Any eligible candidate who wants to be included on the ballot must submit the relevant information via the candidate profile form to FINRA’s Office of the Corporate Secretary by Friday, October 1, 2021.

FINRA Requests for Comment

FINRA is requesting comment on potential enhancements to its short sale reporting program in Regulatory Notice 21-19. FINRA is considering: (1) modifications to its short interest reporting requirements (Rule 4560); (2) a new rule to require that participants of a registered clearing agency report to FINRA information on allocations to correspondent firms of fail-to-deliver positions; and (3) other potential enhancements related to short sale activity. The comment period has been extended to September 30, 2021.

FINRA is requesting comments on its Cloud Computing in the Securities Industry report, including areas where guidance or modifications to FINRA rules may be desired to support cloud adoption while maintaining investor protection and market integrity. Comments are requested by October 16, 2021.

FINRA requests comment in Regulatory Notice 21-32 on a proposed change to its current policy relating to the assignment of OTC symbols to unlisted equity securities. Specifically, FINRA is considering whether it should begin assigning OTC symbols to unlisted equity securities that do not have a valid CUSIP identifier, in the limited circumstance where a member firm demonstrates its best efforts to obtain a CUSIP identifier and provides documentation to identify the security. Comments are requested by November 15, 2021.

 Education and Compliance Programs

The agenda is now available for FINRA’s Virtual Diversity Leadership Summit on September 28 – 30, 2021. Hear from diversity practitioners and business leaders as they share innovative ideas and effective practices to promote diversity, equity and inclusion in the workplace. Register today!

Registration is now open for the Compliance Outreach Program for Municipal Advisors on October 7 from 10 a.m. – 5 p.m. ET. This free webcast program will provide municipal advisors and other municipal market participants an opportunity to hear from SEC, MSRB and FINRA staff on timely regulatory and compliance matters. View the detailed agenda for session descriptions.

Participate in our fall Virtual Compliance Boot Camps starting this October. These one-hour interactive virtual classroom sessions include training on a variety of topics including Cybersecurity and Anti-Money Laundering (AML) and provide an opportunity to learn from and work closely with FINRA subject matter experts in a small group setting. Participants gain valuable insights on compliance activities for immediate application in the workplace. Registration is open for our Cybersecurity sessions, with AML sessions coming soon.

Register today to join the FINRA Investor Education Foundation, FINRA's Office of the Chief Economist, and NORC at the University of Chicago for the 2021 Access and Impact Conference: Gauging the Participation of Diverse Communities in the Capital Markets. During this free virtual event on October 22, panelists examine methods and impacts of increasing access or reducing impediments to the provision of financial services to diverse communities. View the agenda for more information and session descriptions.

Register for all of FINRA’s upcoming events:

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