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FINRA Alerts Member Firms Not to Close/Withdraw Form BR in any Jurisdiction or With any SRO That has Branch Office Registration/Notice Filing Requirements

June 18, 2024

FINRA understands that certain jurisdictions and SROs that require a branch office to be either “registered” or “notice filed,” using Form BR (Uniform Branch Office Registration Form) may not currently be able to recognize FINRA Rule 3110.19 (Residential Supervisory Location (“RSL”)). At this time, Form BR does not generally allow a member firm to select or deselect individual jurisdictions or FINRA or other SROs. We are working with jurisdictions and SROs to add functionality to CRD that will allow member firms to select or deselect any individual regulator for an office/location without impacting such office/location’s registration status with other jurisdictions or SROs. Until FINRA provides further notice or instruction, FINRA alerts member firms not to close/withdraw any existing Form BR for those locations that are or will be designated as an RSL. During such time, if a location remains reported as a FINRA registered branch office on Form BR, is listed by the member firm as an RSL in their internal records, and the member firm is otherwise in compliance with the requirements of Rule 3110.19, FINRA will recognize the member firm’s designation of such location as an RSL nonbranch location and not as a FINRA registered branch office. As previously announced, FINRA is separately working to amend the Form U4 to add an “RSL Checkbox” that will allow member firms to comply with the reporting requirement under FINRA Rule 3110.19(d). Until such functionality is available, member firms should maintain an internal list of all RSL locations. FINRA will provide updated guidance in the near future.