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Residential Supervisory Locations (RSLs)

Under Rule 3110.19, a “residential supervisory location” (or RSL) is generally defined as a private residence from which an associated person engages in supervisory functions, including those described in FINRA Rule 3110(f)(1)(D), (E), (F) and (G), and FINRA Rule 3110(f)(2)(B).  An RSL is non-branch location, which means that a firm does not need to register it as a branch office under Article IV, Section 8 of the FINRA By-Laws.  As a non-branch location, a firm is required to inspect an RSL on a regular periodic schedule in accordance with FINRA Rule 3110(c)(1)(C) and FINRA Rule 3110.13.  Starting on June 1, 2024, a firm may start using the RSL designation, subject to the terms set forth under Rule 3110.19. 

In general, to use the RSL designation, a firm and the associated person at each location must meet specified eligibility requirements and conditions.  Among other requirements, a firm must conduct and document a risk assessment, and provide a list of RSLs to FINRA on a periodic basis.  Rule 3110.19(d) requires a member firm that elects to designate any of its offices or locations as RSLs to provide FINRA with a current list of them by the 15th day of the month following each calendar quarter in the manner and format (e.g., through an electronic process or such other process) as FINRA may prescribe.

As member firms determine which offices or locations may be eligible for RSL designation, firms are reminded of their obligations to maintain updated Form U4 (Uniform Application for Securities Industry Registration or Transfer) information regarding the office of employment address for registered persons who temporarily relocated due to the pandemic and as applicable, to submit branch office applications on Form BR (Uniform Branch Office Registration Form) to register their branch offices.  While Regulatory Notice 20-08 (Notice 20-08 Relief) temporarily suspended these obligations due to the pandemic, the Notice 20-08 Relief ends on May 31, 2024.

  • FINRA Adopts FINRA Rule 3110.19 (Residential Supervisory Location) and FINRA Rule 3110.18 (Remote Inspections Pilot Program), and Announces End of Temporary Relief Related to Updates of Office Information on Forms U4 and BR
  • SEC Approves New Supervision Rules
  • FINRA and the SEC Issue Joint Guidance on Effective Policies and Procedures for Broker-Dealer Branch Inspections
  • SEC approves amendments to NASD Rule 3010(g)(1) to Exempt Locations that Solely Conduct Final Approval of Research Reports
  • Extension of Effective Date of NASD Uniform Branch Office Definition and Certain Form BR and Form U4 Filing Requirements from May 1, 2006 to July 3, 2006, Effective Date of Uniform Definition: NASD: July 3, 2006
  • SEC Approves Uniform Branch Office Definition and Related Interpretive Material
  • NASD Provides Guidance On Supervisory Responsibilities
  • NASD Reminds Members Of Supervisory And Inspection Obligations
  • Guidelines For Compliance With Article III, Section 27 of the NASD Rules of Fair Practice Re: Supervisory Practices and Procedures
  • SEC Approval of Amendments to NASD Rules of Fair Practice and Conforming Amendments to the By-Laws Re: Supervisory Practices and Definitions of Branch Office and Office of Supervisory Jurisdiction
May 31, 2024End of Regulatory Notice 20-08 Relief
May 31, 2024Release of FINRA Gateway functionality for firms to identify their RSLs and meet the obligation to provide their quarterly RSL lists to FINRA in accordance with Rule 3110.19(d)
June 1, 2024

Rule 3110.19 effective date

The first day a firm may use the RSL designation.

June 1, 2024Date on which firms previously relying on the Notice 20-08 Relief must comply with the timeframes specified in Article V, Section 2 or Article IV, Section 8 of the FINRA By-Laws.
July 1, 2024Date by which firms previously relying on the Notice 20-08 Relief must file supplementary amendments to Form U4 and BR with FINRA in accordance with Article V, Section 2 or Article IV, Section 8 of the FINRA By-Laws.
October 15, 2024

Date by which firms must submit the first RSL list to FINRA

The first list will reflect all locations a firm designates as RSLs during the period June 1, 2024, through September 30, 2024.