The Membership Interview

The membership interview is a meeting between FINRA, the Applicant, and the Applicant’s representatives. Representatives from FINRA will typically include the Membership Application Program (MAP) Group staff processing the application, the Risk Monitoring team that will be assigned to the Applicant if the application is approved and representatives of other departments within FINRA as needed. An email will be sent to the Applicant, or the Applicant’s designee, with the date and time of the interview and who on the firm side is expected to attend.  

The Applicant may bring other appropriate persons to the interview, such as consultants or attorneys; however, FINRA staff wants to hear specifically from the Applicant during the interview. The location of the interview will be discussed prior to scheduling. 

The membership interview serves several important purposes: 

  1. The interview enables FINRA MAP Group staff to discuss any open, unresolved issues, problems or concerns about the application, which MAP Group staff will identify to the Applicant in advance of the interview.  
  2. The interview affords FINRA staff the opportunity to question the Applicant's representatives and gather additional information to assist in determining whether the Applicant meets the membership standards.  
  3. The interview affords the Applicant an opportunity to ask questions about the process, FINRA Rules and to gather other information relating to the regulation of a broker-dealer.  
  4. The interview enables FINRA staff to provide key information to the Applicant in order to help ensure that, if the application is approved, the Applicant is cognizant of its obligations as a member firm.  

The membership interview should be viewed as part of the overall review of the Applicant. 

During the membership interview, the participants will discuss substantially all aspects of the Applicant's proposed business for which they will have regulatory and compliance responsibilities. Emphasis throughout the membership interview will be placed on the rules applicable to the Applicant's intended business, the Applicant's supervisory structure, the background and experience of the Applicant's principals and representatives, and plans for future direction and expansion. Questions about how the Applicant will comply with FINRA’s rules, how it will process transactions, and how it will supervise activities, among other things, must be answered by the individual or individuals associated with the Applicant who will be responsible for those functions. The focus of the discussions during the membership interview will relate to the Applicant's ability to meet the Standards for Admission set forth in FINRA Rule 1014.

Membership interviews are designed to provide for an exchange of information between FINRA staff and persons associated with the Applicant who are qualified to provide FINRA with requested information. Persons who do not meet that profile may be excluded from the meetings due to the confidentiality of the proceedings or when the presence of such persons would not add to the process. This should not preclude the Applicant from having attorneys or consultants assist with, or attend, the membership interview. FINRA Rules 1013(b) and 1017(g) govern membership interviews for new member applications (NMAs) and continuing member applications (CMAs), respectively.