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Regulatory Notice 08-01

Broker-Dealer, Investment Adviser Firm, Agent and Investment Adviser Representative, and Branch Renewals for 2008

Published Date:
Payment Deadline: February 4, 2008

BD and IA Renewals for 2008

Regulatory Notice

Notice Type

Renewals

Referenced Rules & Notices

NTM 02-48
Suggested Routing

Compliance
Legal
Operations
Registered Representatives
Registration
Senior Management
Key Topic(s)

CRD®
Renewals
Registration
IARDSM

Executive Summary

FINRA is issuing this Notice to help firms review, reconcile and respond to their Final Renewal Statements and reports that are currently available on Web CRD and IARD for the 2008 registration renewal process.

Questions concerning this Notice should be directed to the FINRA Gateway Call Center at (301) 869-6699.

Background & Discussion

Final Renewal Statements

On January 2, 2008, Final Renewal Statements and reports became available for viewing and printing. These statements reflect the final status of broker-dealer, registered representative (AG), investment adviser firm and investment adviser representative (RA) registrations and/or notice filings as of December 31, 2007. Any adjustments in fees owed as a result of registration terminations, approvals, firm IA registrations or notice filings subsequent to the Preliminary Renewal Statement have been made in this final reconciled statement.

•  If a firm had more agents, branch offices or jurisdictions registered and/or notice filed on Web CRD and IARD at year-end than it did when the Preliminary Renewal Statement was generated, additional renewal fees were assessed.
•  If a firm had fewer agents, branch offices or jurisdictions registered and/or notice filed at year-end than it did when the Preliminary Renewal Statement was generated, a credit/refund was issued. Please note that overpayments were systematically transferred to firms' Daily Accounts on January 2, 2008. Firms that have a credit (sufficient) balance in their Daily Account may request a refund by mailing or faxing a written request signed by the designated signatory to:

FINRA Finance Department
9509 Key West Avenue
Rockville, MD 20850
Phone: (301) 869-6699
Fax: (240) 386-5344

The request should include a printout of the firm's credit balance as reflected on Web CRD.

The Final Renewal Statement includes the following fees:

•  Web CRD system processing fees;
•  FINRA branch office fees;
•  FINRA branch renewal processing fees;
•  American Stock Exchange (AMEX), Boston Stock Exchange (BSE), Chicago Board Options Exchange (CBOE), International Securities Exchange (ISE), NASDAQ Stock Exchange (NQX), NYSE Arca, Inc. (ARCA) and Philadelphia Stock Exchange (PHLX) maintenance fees;
•  state agent renewal fees;
•  state BD renewal fees;
•  state BD branch fees;
•  investment adviser firm and representative renewal fees, if applicable; and
•  broker-dealer and/or investment adviser branch renewal fees.

FINRA must receive full payment of the Final Renewal Statement no later than February 4, 2008.

Renewal Payment

A Final Renewal Statement that reflects a zero balance requires no further action.

On January 2, 2008, all renewal overpayments were systematically transferred to firms' Daily (registration) Accounts. If you believe your firm is due a renewal refund, please check your firm's Daily Account to verify that funds are available. To request a refund check, have an appropriate signatory send a request on firm letterhead to:

FINRA Finance Department
9509 Key West Avenue
Rockville, MD 20850
Phone: (301) 869-6699
Fax: (240) 386-5344

If the Final Renewal Statement reflects an amount due, FINRA must receive payment no later than February 4, 2008. Firms have four payment options:

1. New for 2008: Automatic Daily-to-Renewal Account Transfer
2. Web CRD/IARD E-Pay
3. Check
4. Wire transfer

Automatic Daily-to-Renewal Account Transfer

To facilitate Renewal payment processing for all firms, FINRA will automatically transfer funds from a firm's Daily Account to its Renewal Account on February 4, 2008, the Final Renewal Statement payment deadline. FINRA will transfer funds only if a firm has sufficient funds available in its Daily Account on February 4 to cover the amount. Please Note: If a firm does not want funds automatically transferred from its Daily Account to its Renewal Account, the firm should ensure that its payment is received in its Renewal Account by the February 4 deadline. Separately, if a firm wishes to transfer funds between affiliated firms, the firm should contact the FINRA Gateway Call Center at (301) 869-6699 for further instructions prior to the renewal deadline.

Web CRD/IARD E-Pay

The Web CRD/IARD E-Pay application is accessible from the Final Renewal Statement and the FINRA (www.finra.org/crd) or IARD (www.iard.com) Web sites and allows firms to make an ACH payment from a designated bank account to their Web CRD/IARD Renewal Account. Please note that in order for funds to be posted to your firm's Renewal Account by February 4, 2008, payment must be submitted electronically, no later than 8:30 p.m. ET on January 31, 2008.

Check

The check should be drawn on the firm's account, with the firm's CRD number included on the front of the check, along with "Renewal" in the memo line. Firms should mail their renewal payment, along with a print-out of the first page of their online renewal statement, directly to:

U.S. Mail

FINRA
P.O. Box 7777-8705
Philadelphia, PA 19175-8705
(Note: This box will not accept courier or overnight deliveries.)

or

Express/Overnight Delivery

FINRA
8705
Mellon Bank Room 3490
701 Market Street
Philadelphia, PA 19106
Telephone: (301) 869-6699

Please note: The addresses for renewal payments are different than the addresses for funding CRD or IARD Daily Accounts.

To ensure prompt processing of your renewal payment check:

•  Include a printout of the first page of your Final Renewal Statement with payment.
•  Do not include any other forms or fee submissions.
•  Write your firm's CRD number and "Renewal" on the check memo line.

Wire Payment

Firms may wire full payment of the Final Renewal Statement by requesting their bank to initiate the wire transfer to: "Mellon Financial, Philadelphia, PA." Firms should provide their bank the following information:

Transfer funds to: Mellon Financial, Philadelphia, PA
ABA Number: 031 000 037
Beneficiary: FINRA
FINRA Account Number: 8-234-353
Reference Number: Firm CRD number and "Renewals"

To ensure prompt processing of a renewal payment by wire transfer:

•  Remember to inform the bank that the funds are to be credited to the FINRA bank account.
•  Provide the firm's CRD number and "Renewal" as reference only.
•  Record the confirmation number of the wire transfer provided by the bank.

Renewal Reports

Renewal reports include all individual registrations renewed for 2008. Registrations that were "pending approval" or were "deficient" at year-end 2007 were not assessed renewal fees; therefore, they will not be reported on the Firm (Agent) Renewal Report. Firms should examine their reports carefully to ensure that all registration approvals are properly listed. It is also suggested that these reports be made a permanent part of firms' records.

Firm Renewal Report: applicable to broker-dealer and investment adviser firms. This report lists all renewed personnel with FINRA, AMEX, ARCA, BSE, CBOE, ISE, NQX, PHLX and/or each jurisdiction. Individuals whose registrations were "approved" with any of these regulators during November and December will be included in this report, while registrations that were still pending approval or were deficient at year's end were not included in the 2008 Renewal Program nor will they be listed on the report. Firms should use this report to reconcile their records for renewal purposes.

Branches Renewal Report: applicable to both broker-dealer and investment adviser firms. This report lists each branch registered with FINRA and other regulators that renew branches registered with them through Web CRD/IARD for which the firm was assessed a fee. Firms should use this report to reconcile their records for renewal purposes.

Discrepancies

If a firm finds any discrepancies between its records and those maintained on Web CRD/IARD, the discrepancy must be reported, in writing, to FINRA at:

FINRA
Registration Management-CRD Accounting
9509 Key West Avenue
Rockville, MD 20850 (301) 869-6699

All discrepancies should be reported by February 4, 2008. Copies of appropriate documentation, such as a Web CRD-generated notice of termination, notification of deficient condition or notice of approval from the firm's Web CRD/IARD queues, should be readily available.

The 2008 Renewal Program Bulletin contains detailed instructions to help firms complete the renewal process. This publication can also be found at www.finra.org/renewals.