FINRA recently released a notice about 2021 and first quarter of 2022 FINRA Report Filing Due Dates to assist members in their financial reporting obligations for Annual Report, Financial and Operational Combined Uniform Single (FOCUS), Form Custody, and supplemental FOCUS Report filings.
Remember that all filings submitted to FINRA must be made electronically through FINRA Gateway. Additionally, the SEC has adopted changes to FOCUS reporting requirements in connection with security-based swaps. Prior to implementation of the changes, FINRA will separately provide guidance and instructions for reporting through FINRA Gateway
Annual Reports
Members are required to file their Annual Report with FINRA electronically, as well as at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, D.C. Make sure to check out the SEC’s process for electronic filing here, as they simplified and updated in 2017. Also, if your firm is a member of the SIPC, you will have to file the Annual Report with them as well, but that is automatically done when filing through the FINRA gateway.
Filings are due no later than 11:59 p.m. Eastern Time (ET) on the due dates listed below.
Annual Reports: Period Ending and Due Dates
November 30, 2020 – Due: January 29, 2021
December 31, 2020 – Due: March 1, 2021
January 31, 2021 – Due: April 1, 2021
February 28, 2021 – Due: April 29, 2021
March 31, 2021 – Due: June 1, 2021
April 30, 2021 – Due: June 29, 2021
May 31, 2021 – Due: July 30, 2021
June 30, 2021 – Due: August 30, 2021
July 31, 2021 – Due: September 29, 2021
August 31, 2021 – Due: November 1, 2021
September 30, 2021 – Due: November 29, 2021
October 31, 2021 – Due: December 30, 2021
November 30, 2021 – Due: January 31, 2022
December 31, 2021 – Due: March 1, 2022
FOCUS Reports
Firms must file FOCUS Reports electronically through the eFOCUS System available via FINRA Gateway. For more guidance, click here.
Monthly and Fifth FOCUS Part II/IIA Filings: Period Ending and Due Dates
January 31, 2021 – Due: February 24, 2021
February 28, 2021 – Due: March 23, 2021
April 30, 2021 – Due: May 25, 2021
May 31, 2021 – Due: June 23, 2021
July 31, 2021 – Due: August 24, 2021
August 31, 2021 – Due: September 24, 2021
October 31, 2021 – Due: November 24, 2021
November 30, 2021 – Due: December 23, 2021
Quarterly FOCUS Part II/IIA Filings: Quarter Ending and Due Dates
December 31, 2020 – Due: January 27, 2021
March 31, 2021 – Due: April 23, 2021
June 30, 2021 – Due: July 26, 2021
September 30, 2021 – Due: October 26, 2021
December 31, 2021 – Due: January 26, 2022
Annual Schedule I Filings: Year and Due Dates
2020 – Due: January 27, 2021
2021 – Due: January 26, 2022
Form Custody
Firms are required to file Form Custody pursuant to SEA Rule 17a-5(a)(5).
Form Custody Filings: Quarter Ending and Due Dates
December 31, 2020 – Due: January 27, 2021
March 31, 2021 – Due: April 23, 2021
June 30, 2021 – Due: July 26, 2021
September 30, 2021 – Due: October 26, 2021
December 31, 2021 – Due: January 26, 2022
Supplemental Statement of Income (SSOI)
Firms must file the SSOI on a quarterly basis.
SSOI Filings: Quarter Ending and Due Dates
December 31, 2020 – Due: February 1, 2021
March 31, 2021 – Due: April 28, 2021
June 30, 2021 – Due: July 29, 2021
September 30, 2021 – Due: October 29, 2021
December 31, 2021 – Due: January 31, 2022
Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (Form OBS)
Unless subject to the de minimis exception, firms must file Form OBS as of the last day of a reporting period within 22 business days of the end of each calendar quarter by using the eFOCUS system. The Form OBS must be filed by: (1) All FINRA member firms that self-clear their proprietary transactions or clear transactions for others or carry customer accounts; and (2) All other FINRA member firms that have, pursuant to SEA Rule 15c3-1, a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable items pursuant to the Form OBS.
Firms claiming de minimis exception must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period.
Form OBS Filings: Quarter Ending and Due Dates
December 31, 2020 – Due: February 3, 2021
March 31, 2021 – Due: April 30, 2021
June 30, 2021 – Due: August 2, 2021
September 30, 2021 – Due: November 2, 2021
December 31, 2021 – Due: February 2, 2022
Supplemental Inventory Schedule (SIS)
The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, unless the firm has: (1) a minimum dollar net capital or liquid capital requirement of less than $100,000; or (2) inventory positions consisting only of money market mutual funds.
SIS Filings: Month Ending and Due Dates
December 31, 2020 – Due: February 1, 2021
January 31, 2021 – Due: March 1, 2021
February 28, 2021 – Due: March 26, 2021
March 31, 2021 – Due: April 28, 2021
April 30, 2021 – Due: May 28, 2021
May 31, 2021 – Due: June 28, 2021
June 30, 2021 – Due: July 29, 2021
July 31, 2021 – Due: August 27, 2021
August 31, 2021 – Due: September 29, 2021
September 30, 2021 – Due: October 29, 2021
October 31, 2021 – Due: November 30, 2021
November 30, 2021 – Due: December 29, 2021
December 31, 2021 – Due: January 31, 2022
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