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Evangeline Mellon

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Aug 2, 2024, 7:22:14 PM8/2/24

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Form CMA is organized by 14 standards for admission as set forth under Rule 1014(a) and specifies the documents and information required to support each standard. The items listed in this checklist are also organized by standard and focus on the standards and their related documentation and information that an applicant may inadvertently overlook when submitting the application. Firms should treat this checklist as a starting point for preparing Form CMA. Firms are advised to review the rules applicable to a CMA, including Rules 1014 and 1017, together with Form CMA. During the course of the review process, FINRA may request additional documents and information as necessary to render a decision on the application.

To submit Form BD or BDW filings, your Web CRD user(s) with appropriate entitlement should access Web CRD. If you have questions about whether succession rules apply, contact the SEC's Office of Interpretive Guidance at (202) 551-5777.

The Mass Transfer Program allows for the transfer of registration information in mass for qualified individuals when a firm is involved in any one of the following, and which involves at least 50 individuals: Acquisitions (Successor), Asset Purchases, Consolidations, Mergers and Successions. If the organizational change qualifies for a mass transfer, the representatives will be systematically terminated with the predecessor firm and registered with the successor firm without requiring submission of Form U4 filings, Form U5 filings, and fingerprint cards. To learn more about the mass transfer process and whether it would be suitable for your firm, contact the FINRA Support Center at (301) 869-6699 and ask to speak with a mass transfer representative.

If your representatives will be moved from one firm to another without a mass transfer, Form U4 filings and fingerprint transactions must be submitted to register the representatives with the new firm, and Form U5 filings will be required for any representatives who will be terminated from their current firm. To submit Form U4 or U5 filings, your Web CRD user(s) with appropriate entitlement should access Web CRD.

The successor firm should encourage each registered representative to verify that the information on record is correct, as the successor firm is now responsible for the records (including disclosure information) of these representatives.

If you submitted Form U4 filings to register representatives with the new firm, you may wish to verify that all necessary registrations have been requested. If you moved representatives via a mass transfer, be aware that some states may block mass transfers, so it is important to validate registrations in Web CRD after the mass transfer is complete.

If the predecessor firm is submitting a full Form BDW, the predecessor firm's entitlement accounts will be terminated once the firm termination is complete. The successor firm should consider whether new user accounts are necessary for any of the following systems:

The successor firm's Super Account Administrator (SAA) can create or modify account administrators and users.

If the successor firm has not yet named an SAA or needs to replace the current SAA, the firm should review the instructions on the SAA Entitlement page on how to entitle someone at your firm to serve in this role.

It is the SAA's responsibility to remove entitlement immediately for account administrators or users who are no longer with the firm. An account administrator is also able to modify and/or delete user accounts who no longer require access; however, account administrators cannot alter the access of another account administrator - that can only be performed by an SAA. User accounts are deleted via the FINRA Account Management tool. See the FINRA Entitlement Program: Entitlement Reference Guide for more information and navigational support.

If the firm is filing a full Form BDW filing to terminate, the firm also needs to submit written notice to disable its FINRA Participation Agreement. The FINRA Participation Agreement can be found on the Transparency Services Legal Agreements page.

A new signed contract is required when a merger occurs. The TRACE Order Form enables you to request, modify, or terminate your TRACE service. The TRACE Order Form can be found on the Transparency Services Legal Agreements page.

In order for a firm to give other organization(s) permission to transmit on the firm's behalf, the relationship needs to exist in OATS. See Chapter 6 of the OATS Web Interface User Guide for instructions on accessing, creating, and modifying firm relationships.

If the predecessor firm has open limit orders on their books that will be executed under the successor firm's MPID, the firm should route the orders to the new MPID, and report the route to OATS, or provide the predecessor's Broker/Dealer Number in the "Originating Broker/Dealer Number" field on the OATS report.

FINRA has seen instances, during organizational changes, of non-reporting of required order events because the firm has not clearly identified all departments and/or individuals responsible for OATS submissions. You should verify that all departments are submitting to OATS as required.

FINRA Member firms are required to update contact information via the FINRA Contact System (FCS) within 30 days following any changes and to review required contact information annually, pursuant to NASD Rule 1160. For questions, contact the FINRA Support Center at (301) 869-6699.