Regulatory Notice 18-30

Enhancements to the REX System and Updates to Data and Other Requirements Applicable to Requests for Extensions of Time Under Regulation T and SEA Rule 15c3-3

Effective Date: December 3, 2018 (enhancements to the REX System to provide firms the ability to submit Securities Exchange Act (SEA) Rule 15c3-3(d)(4) extension of time requests via a batch file process and other updates to the extension of time request forms); February 25, 2019 (updates to data and validation requirements for extension of time requests under Regulation T and SEA Rule 15c3-3)

The effective date of the online enhancements and the ability to file SEA Rule 15c3-3(d)(4) extensions of time requests via the batch process will be delayed to January 7, 2019 (rather than December 3, 2018). The second Testing Cycle will still start on December 10, 2018 (rather than December 3, 2018) and end on February 18, 2019.


Effective on December 3, 2018, FINRA will update the Regulatory Extension (REX) system to improve the process for requesting extensions of time required under SEA Rule 15c3-3 and FINRA Rule 4210. Specifically, the changes will provide firms the ability to submit SEA Rule 15c3-3(d)(4) extension of time requests via a batch file process and add functionality to enhance the process by which firms request extensions of time under FINRA Rule 4230(a), SEA Rule 15c3-3(d), (m) and (h), and file the reports required under FINRA Rule 4230(b). Further, effective on February 25, 2019, firms will no longer be required to submit a customer’s complete Social Security or tax identification number, and shall instead submit the last four digits of such numbers when requesting extensions of time under Rule 4230(a). In addition, FINRA is updating certain validation identifiers and validation criteria that will affect the extension timeframes available to meet Regulation T calls. These updates are further detailed in Appendix A of this Notice.

Questions concerning this Notice may be directed to:

  • Adam Rodriguez, Director, Credit Regulation, at (646) 315-8572;
  • Peter Grassi, Principal Specialist, Credit Regulation, at (212) 416-1786; or
  • Theresa Reynolds, Senior Credit Specialist, Credit Regulation, at (646) 315-8567.