2026 Customer Information Request – FAQs | FINRA.org

2026 Customer Information Request – FAQs

These Frequently Asked Questions (FAQs) provide guidance that pertains specifically to the 2026 Customer Information Request (CIR). Please direct questions not addressed below to your firm’s Risk Monitoring Analyst (RMA). For technical assistance with accessing or submitting the request through FINRA Gateway, contact the FINRA Support Center at (800) 321-6273 or via email. 

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GENERAL QUESTIONS

1. If a firm has questions regarding the 2026 CIR, who should it contact?

For technical assistance accessing or submitting the request through FINRA Gateway, a firm should contact the FINRA Support Center at (800) 321-6273 or [email protected]. For general process or content questions, a firm should contact its RMA. 

2. Is a response required?

Although participation is voluntary, comparable Customer, Vendor and Crypto Asset information requests have received response rates exceeding 95 percent during the past two years. A firm’s responses help FINRA understand the firm’s business and customers, tailor engagement, assess the firm’s exposure to regulatory changes and emerging industry risks, and to more effectively allocate oversight resources. 

3. When are responses due?

FINRA has requested firms submit their responses by Nov. 18, 2026. The CIR was sent to more than 2,400 firms on Oct. 7, 2026, requesting information about their customer base as of Sept. 30, 2026. 

4. Is there a way for a firm to print or download the request?

Firms may download the CIR as an Excel file, distribute it for completion, and then upload the completed file to populate the final form in FINRA Gateway. A Sept. 30, 2026, email and subsequent firm communications included a link to instructions for downloading the Excel file. Please visit FINRA’s website for additional information.

5. Can a firm amend its previously submitted CIR response? If so, how does it amend?

Yes. Firms are encouraged to submit an amendment whenever they or their RMA identify an inaccurate or incomplete response. Amendments may be submitted after Nov. 18, 2026. A user with the appropriate entitlement can locate the submission on the Completed tab under Requests & Filings in FINRA Gateway and select Create Amendment. Once created, an amendment must be submitted, even if it was opened in error and contains no changes.

CUSTOMER AND CUSTOMER ACCOUNT DEFINITIONS

6. For purposes of this request what is an Institutional Customer?

An Institutional Customer is defined consistently with FINRA Rule 4512(c). See “Definition of Institutional Customer” in the CIR for further details. 

7. For purposes of this request what is a Non-Institutional Customer?

A Non-Institutional Customer is a customer that does not meet the definition of an Institutional Customer. The Institutional and Non-Institutional categories are intended to capture all customer relationships. See “Definition of Non-Institutional Customer” in the CIR for further details. 

8. For purposes of this request what is a Foreign Customer?

A Foreign Customer is defined as an Institutional or Non-Institutional customer who is not a U.S. person or has at least one beneficial owner who is not a U.S. person, consistent with the definition within the CIR.  

9. For purposes of this request what is the difference between a customer and a customer account?

A single beneficial owner may hold multiple accounts, and some business models serve customers without traditional brokerage accounts. For institutional relationships, a firm may treat the customer as the master relationship and individual accounts as subaccounts. Firms should report all open accounts, regardless of activity.

10. May a firm use household-level data when it does not maintain readily available individual customer counts?

Yes. Consistent with providing approximate information, a firm may respond at the household level if that is how it maintains readily available statistics.

11. Should a correspondent clearing firm customer responses include customers of its introducing broker-dealers?

No. Customers of introducing broker-dealers are reported by the introducing firms. A correspondent clearing firm should report its direct customers and complete the correspondent-clearing portion of the CIR as applicable.

12. Should a firm include customers or accounts beneficially owned by a broker-dealer?

Yes. Responses should include entity-type relationships, including broker-dealer clients whose accounts are serviced by the firm. The firm may provide explanatory context in the Additional Information and Comments field.

FIRMS WITHOUT ANY CUSTOMERS

13. What information should a firm without any customers provide?

A firm without any Institutional, Non-Institutional or Foreign Customers should respond “No” to the three initial screening questions (A, B and C) and then submit the request through FINRA Gateway.

HYBRID ACCOUNTS – BOTH SELF-DIRECTED AND TRADE WITH RECOMMENDATIONS

14. For question 16, how should a firm report an account that includes self-directed trading and trading resulting from recommendations?

A firm should include an account in the solely self-directed population only if all the account activity is self-directed or unsolicited. If an account includes trades that are both self-directed and solicited or from firm recommendations, it should be reported in the population of accounts for which the firm makes recommendations.

APPLICATION WAY, DIRECT APPLICATION AND SUBSCRIPTION-BASED PRODUCTS

15. For question D. what does FINRA mean by Application Way, Subscription Way, Direct Business or Direct Application products?

These terms generally describe securities transactions in which a representative assists a customer with an application or subscription while the product is held directly with an issuer, transfer agent, custodian or other party rather than within a traditional brokerage account. If no available transaction-method category applies, a firm may select Other and provide a description. Additional reference information can be found within the SEC Frequently Asked Questions on Form CRS.

DVP/RVP ACCOUNTS

16. How should a firm report DVP/RVP accounts?

Firms’ responses for Institutional and Non-Institutional account information should include DVP/RVP accounts. If an account has no ending account value as of Sept. 30, 2026, a firm should report $0 value for that account.

INVESTMENT BANKING AND PRIVATE PLACEMENT FIRMS

17. How should private placement or unregistered-offering firms report customers, accounts and ending values?

Private placement and wholesaler firms generally should not include issuer-only relationships in their customer responses. Customers generally include relationships and accounts subject to Know Your Customer, Form CRS or Regulation Best Interest requirements. Firms should consider whether they or their associated persons assist in the facilitation of a customer’s subscription agreement or payment—for example, by helping complete or submit a subscription agreement or payment. Customer information responses should also align with the SEC Frequently Asked Questions on Form CRS.

If the firm does not maintain a traditional account or ending value, it may use approximate customer sales or original investment values for the applicable CIR period and explain the approach.   

18. How should M&A, corporate advisory and investment banking firms respond?

Responses should reflect securities transactions involving Institutional, Non-Institutional or Foreign Customers, including underlying investors in offerings. Issuers or corporate advisory clients should not be included solely because the firm advises them on an M&A or investment banking engagement.

NON-SECURITY INSURANCE CUSTOMERS

19. Should a firm include non-security insurance customers?

No. A firm should provide responses for customers investing in securities products, such as variable products or mutual funds processed through direct application arrangements. Customers solely transacting in fixed insurance products that are non-securities should not be included. 

RIA AND Non-FINRA RSA CUSTOMERS

20. How should a firm treat customers serviced through an RIA relationship or a Non-FINRA Member RSA?

RIA-related customers are included when the FINRA member is the broker-dealer of record, including fully introduced and direct application relationships. Broker-dealer activities under an RSA are within scope to the extent the firm has customers.

FIRMS UNDERGOING A CMA

21. How should a firm respond if it is undergoing a continuing membership application?

For a pending transfer of customers or accounts, the firm should report on its customer base as of the Sept. 30, 2026, response date.

FIRMS UNDERGOING A FINRA FIRM EXAM

22. How should a firm respond if it is currently undergoing a FINRA firm exam?

A firm currently undergoing a FINRA exam should treat the CIR as unrelated to any requests pertaining to the examination and should respond to them separately. 

WHOLESALER/DISTRIBUTOR TYPE FIRMS

23. How should a wholesaler or distributor-only firm respond?

A firm should provide responses for direct customers for which it provides broker-dealer services. It should not include entities solely because it has a distribution agreement with them. If a wholesaler or distributor-only firm does not have any direct customers, it should answer the three screening questions accordingly.

FIRMS WITH ATS OR NON-ATS BATCHING SYSTEMS

24. How should an ATS or non-ATS batching system report customers?

Subscribers generally should be treated as customers. A subscriber includes a person with a contractual agreement to access the system to effect securities transactions or submit, disseminate or display orders, but does not include a national securities exchange or national securities association.

FIRMS THAT DO NOT TRACK CUSTOMERS OR CUSTOMER ACCOUNTS

25. What should a firm do if it does not track all data requested by the CIR?

The firm should make its best effort to provide actual or approximate numbers and values using available information. Additionally, it should explain material assumptions, limitations or alternate data sources in the “Additional Information and Comments” response section.

FIRMS THAT REQUEST AN EXTENSION OF TIME

26. How should a firm inform FINRA its responses will be submitted subsequent to Nov. 18, 2026.

A firm should notify its RMA of the delay, provide the expected submission date, and briefly explain the reason, such as resource constraints, technical issues with obtaining certain information, etc. 

FOREIGN CUSTOMERS AND CUSTOMER ACCOUNTS

27. What information should a firm consider when responding to question 18a.,  about Foreign Accounts associated with China, Hong Kong or Macau?

A firm’s response should include accounts for which its customer records and/or supervisory systems reflect as having ownership or a controlling relationship by a natural person and/or legal entity that is domiciled or created in China, Hong Kong or Macau. A firm generally is not required to look through a trust solely for this purpose, but its AML program must be risk based.

POLITICALLY EXPOSED PERSONS (PEPS)

28. For question 17 how should a firm identify Politically Exposed Persons (PEPs)?

A firm’s response should include any customer for which its customer records and/or supervisory systems reflect PEP ownership, as defined by the Financial Action Task Force (FATF), or control relationship. A firm generally is not required to look through a trust solely for this purpose, but its AML program must be risk based.   

15a-6 CHAPERONE FIRMS

29. How should SEC Rule 15a-6 chaperone firms respond?

A chaperone firm should report direct customers and relationships for which it has a Know Your Customer obligation. It should report the clients for which it facilitates chaperoning services, but not underlying subaccounts used for allocations.

APPROXIMATE RESPONSES

30. May a firm use information from a nearby month-end instead of the exact CIR measurement date?

A firm may use available customer data if it does not materially differ from data as of the requested response. In such cases, a firm can explain its methodology in the CIR Additional Information and Comments field.

TRUSTED CONTACTS AND BENEFICIARIES 

31. For purposes of question 11, should a power of attorney be treated as a Trusted Contact?

Holding power of attorney does not, by itself, make a person a Trusted Contact. A person may be separately designated as a Trusted Contact, but that role does not grant authority over the account or permit trading decisions.

32. What information may firms provide in response to the new 2026 question 6b. regarding registered representatives who are named beneficiaries or hold a similar position of trust for a Non-Institutional account. 

FINRA Rule 3241 (Registered Person Being Named a Customer’s Beneficiary or Holding a Position of Trust for a Customer) requires member firms with which a registered person is associated, upon receiving required written notice from the registered person, to review and approve or disapprove the registered person assuming such status or acting in such capacity. The rule does not apply where the customer is a member of the registered person’s “immediate family.” For additional information see  FINRA Regulatory Notice 20-38. A firm may respond with the number of Non-Institutional accounts for which the assigned registered person has received approval to be named a beneficiary or to hold a position of trust pursuant to FINRA Rule 3241. 

SPECIFIED ADULT ACCOUNTS AND FINRA RULE 2165

33. What information may firms provide in response to the new 2026 questions regarding temporary holds under FINRA Rule 2165 (Financial Exploitation of Specified Adults)?

A firm may report the total number of holds on disbursements or transactions that it placed on Specified Adult accounts under FINRA Rule 2165 during the 12-month period ending Sept. 30, 2026. If an account was subject to multiple holds, each hold should be counted. Firms may use the Additional Information And Comments section to provide more context. 

34. For purposes of Question 10 and 10a., what is a Specified Adult and Specified Adult Account?

FINRA Rule 2165 defines a Specified Adult as: a natural person age 65 and older; or a natural person age 18 and older who the firm reasonably believes has a mental or physical impairment that renders the individual unable to protect his or her own interests. A Specified Adult Account means an account for which a Specified Adult has authority to transact business.