Advertising Regulation Voluntary Revised Communication Pilot Program FAQ
1. How do I upload a revision?
Firms choose the “Revised Communication Upload” selection from the “Purpose of Additional Information” dropdown dialog box, select the “Include attachment only” radio button, and upload the revision as an attachment in the Advertising Regulation Electronic Filing (AREF) system under the associated released reference number.
2. What are the time limitations by which a firm must upload a revision?
Firms may participate in this pilot by voluntarily uploading a revision within 45 calendar days from the date of the original review letter.
3. How many times can I upload a revision of a previously filed communication?
The pilot program is limited to one revision for each filing reference number.
4. What changes can be made in the revision?
Changes in the revision must be limited to the issues identified by staff in its original review letter. Communications with changes beyond those necessary to address the concerns identified in the original review letter will not be eligible for the pilot program.
5. Am I required to upload a revision of a previously filed communication for which my firm received a letter from staff indicating that revisions are necessary for compliance with applicable standards?
No. Participation in the pilot is completely voluntary. FINRA Rule 2210 does not require firms to upload a revision when the original review letter received from staff indicates that revisions are necessary for compliance with applicable standards. While the rule does not require revisions to be uploaded, a firm must at least prepare its own revised version of the communication to address the concerns cited in the review letter should it wish to use the communication.