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Subordination Agreements

Generally, brokers and dealers use subordinated loans and notes collateralized by securities (referred to as subordinations) to borrow funds or securities from investors to increase their regulatory net capital. Pursuant to FINRA Rule 4110(e)(1), subordinations must be approved by FINRA in order to receive beneficial regulatory capital treatment.


Standard FINRA Subordination Agreement Templates


How to Submit Subordinated Loans Related Requests

FINRA has implemented a platform to submit Subordinated Loan related requests electronically through the Firm Gateway. For additional information, see Regulatory Notice 15-42.

To ensure you have access to the Subordinated Loans system, contact your firm's Super Account Administrator. For questions regarding the Subordinated Loan System, please contact Firm Gateway support at (301) 590-6500 

Training Resources

Firms User Guide

Need Help?

Please contact the following individuals for any questions related to Subordination agreements:

  • Diana Hernandez, Principal Subordinated Loan Examiner at (646) 315-8476 or by email.
  • Sheryl Martinez, Examination Manager at (212) 858-4135 or by email.
  • FINRA to Require Electronic Submission of Subordination Approval Requests
  • FINRA Announces Updates of the Interpretations of Financial and Operational Rules
  • FINRA Requirements for Subordinations
  • SEC Approves NASD Rule Requiring Members to Require Investors to Sign a Disclosure Document as Part of a Subordinated Loan Agreement
  • Investor Alert
    When you think of investments and brokerage firms, you probably think of opening an account and buying stocks, bonds, or mutual funds. When you enter into a subordination agreement, you are making an investment, but the investment is in the brokerage firm itself.