FINRA Report Filings for Next Year

FINRA has put out a schedule for its member broker-dealers with the due dates for report filings that are due in 2017 or in the first quarter of 2018. This notice serves as a reminder to help FINRA and SEC registered broker-dealers stay compliant by filing reports on or before their required due dates. Late filings can result in fees and in suspension of FINRA membership.

Annual Audit Reports

Like all report filings submitted to FINRA, the annual audit report is to be filed electronically. Additionally, member firms must file the report at the regional office of the SEC in which the firm has its place of business and at the principal office of the SEC in Washington, DC.  Broker-dealers who are members of the Securities Investor Protection Program (SIPC) must also file the annual audit report with SIPC, per SEA Rule 17a-5(d)(6).

Filings are due no later than 11:59 pm ET on the following due dates:

FOCUS Reports

FOCUS Reports must be submitted electronically via the eFOCUS System in the FINRA Firm Gateway.

For Monthly and Fifth FOCUS Part II/IIA filings, the due dates are:

For Quarterly FOCUS Part II/IIA filings, the due dates are:

And for Annual Schedule I Filings, the due dates are:

Form Custody

Pursuant to SEA Rule 17a-5(a)(5), firms are required to file Form Custody. The due dates are as follows:

Form OBS

The Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items, also known as Form OBS must be filed by:

1. all FINRA member firms that self-clear their proprietary transactions, 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 that is greater than or equal to $100,000 and have at least $10 million in reportable items pursuant to Form OBS.

The only exception to this rule is if the firm falls under the de minimis exception. Firms required to file Form OBS must do so by the last day of a reporting period within 22 business days of the end of each calendar quarter. Form OBS can be filed using the eFOCUS system. Firms claiming the de minimis exception must affirmatively indicate that no filing is required for the reporting period. This affirmation is also made within the eFOCUS system.

The due dates for either filing Form OBS or indicating a de minimis exception are:

Supplementary Inventory Schedule

If a firm is required to file FOCUS Report Par II, FOCUS Report Part IIA, or FOGS Report Part I, the firm is also required to file the Supplementary Inventory Schedule (SIS), with inventory positions as of the end of the FOCUS or FOGS reporting period. A firm is exempt from this requirement if it has either:

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.

Firms with inventory positions consisting only of money-market mutual funds must use the eFOCUS system to affirmatively indicate that no SIS filing is required for the reporting period.

The due dates for filing the SIS or for indicating it is not required are:

Supplemental Statement Of Income

Firms must file the Supplemental Statement of Income (SSOI) quarterly. The due dates are as follows: