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FINRA Reminds Firms About the 2020 Renewal Program

Novemer 6, 2019
Volume 45


  • Regulatory Notices
  • UPC Advisory
disciplinary actions

Disciplinary Actions


Upcoming Deadlines and Effective Dates
  • FINRA Request for Comment

Education and Compliance Programs

fileX is a centralized, secure file transfer platform (SFTP) where firms can programmatically send, track and receive files in one place. fileX significantly streamlines the process for submitting bulk filings to FINRA, provides additional options for downloading files from FINRA, and allows for seamless and secure authentication and authorization. fileX supports the following three service methods through which files can be transferred to FINRA: SFTP, REST API and S3 Direct. The key features, benefits, access details of each service and a user guide can be found on our website.

The current phase of transitions is focused on migrating Regulatory Extension (REX) System, INSITE, 4530, and Daily Net Capital Feed. If your firm does not submit filings by batch submission, there is no action required. If your firm is using file transfer for these applications, FINRA will provide detailed information about the fileX platform, required actions, and migration process to the appropriate contacts at your firm.


It’s not too late to register for FINRA’s Senior Investor Protection Conference on November 12 in Washington, DC. This one-day event is dedicated to sharing the most up-to-date regulatory information, effective strategies and solutions for protecting senior investors and vulnerable adults.


Effective Date Delayed to Dec. 2, 2019: Amendments to Expand Published Data Relating to OTC Equity Trading Volume

Weekly aggregate non-ATS volume data is published on a two-week delayed basis for Tier 1 NMS stocks and a four-week delayed basis for Tier 2 NMS stocks and OTC equity securities. To align the implementation of the rule amendments for these data sets, FINRA has modified the initial publication timeframes described in footnote 8 of Regulatory Notice 19-29 as follows:

  • Beginning December 2, 2019, weekly aggregate non-ATS volume data without the de minimis exception will be available starting with the week of November 11, 2019 for Tier 1 NMS stocks.
  • Weekly aggregate non-ATS volume data for Tier 2 NMS stocks and OTC equity securities will continue to be published with the de minimis exception for the weeks of October 28, 2019 and November 4, 2019, published on December 2, 2019 and December 9, 2019, respectively.
  • Beginning December 16, 2019, weekly aggregate non-ATS volume data without the de minimis exception will be available starting with the week of November 11, 2019 for Tier 2 NMS stocks and OTC equity securities.
  • Additionally, monthly aggregate non-ATS volume data without the de minimis exception will be available starting with the month of October 2019, and new non-ATS block-size data will be available starting with the month of October 2019.

Broker-Dealer, Investment Adviser Firm, Agent and Investment Adviser Representative, and Branch Renewals for 2019
The 2020 Renewal Program begins on November 11, 2019, when FINRA makes the Preliminary Statements available to all firms in E-Bill. As described in Regulatory Notice 19-35, the payment deadline is December 16, 2019.

UPC Advisory

The following UPC Advisory were published in the last week:

  • UPC #38-19 PHI, Inc. (PHIKQ, PHIIQ)
  Disciplinary Actions

FINRA publishes disciplinary actions to remind registered representatives and firms of specific conduct that violates FINRA rules and may result in disciplinary action. FINRA posted the following disciplinary item on the website this week:

  • FINRA announced today that Merrill Lynch, Pierce, Fenner & Smith Inc., Raymond James & Associates, Inc., and Raymond James Financial Services, Inc. have agreed to pay a total of approximately $12 million in restitution to customers who incurred excess fees on their investments in 529 savings plans based on the firms’ failures to reasonably supervise 529 plan share-class recommendations.

 Upcoming Deadlines and Effective Dates

FINRA Request for Comment

FINRA and the other participants of the Consolidated Quotation (CQ) Plan and the Nasdaq Unlisted Trading Privileges (UTP) Plan have issued a proposal for adding odd lot quotation information to the Securities Information Processor or “SIP” data feeds. The Plan participants are actively seeking input on the proposal, which is available on both the CTA website and UTP website. Comments are due by November 15, 2019.

 Education and Compliance Programs

FINRA’s 2019 Regulation Best Interest Conference will be held on December 18 in Washington, D.C. This one-day event is designed to bring regulators, executives and industry practitioners together to learn more about the SEC’s Regulation Best Interest (Reg BI). FINRA is offering free registration to the first two attendees from each firm. Register today to reserve your spot.

FINRA is hosting an AML Half-Day Seminar on November 14 in Boca Raton, FL. Register today to reserve your spot.

District compliance events are designed for compliance and legal professionals at FINRA member firms, and offer an opportunity to hear about current regulatory issues while engaging with District Office staff. Review the compliance calendar to see a complete list of events.

Also coming up:

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Regulatory Contacts
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