FINRA New Member Application

Also called a “FINRA NMA”

FINRA Application Requirements

FINRA Standards for Membership
FINRA Application Time Frames

  • Preparation

    During this phase of the application process, FirstMark gathers information from the applicant and its principals in order to assemble the FINRA membership application for filing. All application documents are reviewed for adequacy, scanned, and uploaded electronically into the FINRA Gateway System. Preliminary filings are made with the U.S. Securities and Exchange Commission and the states in which the applicant intends to do business. FirstMark assists the applicant in preparing the official SEC application for broker-dealer registration. Also, the applicant forms the corporate legal entity which will serve as the broker-dealer.

  • Application Filing

    Once all documents have been prepared, reviewed and scanned, the draft of the application is presented to the principal officers of the proposed broker-dealer for review. Upon approval, FirstMark files the application electronically and awaits FINRA’s assignment of an examiner and prepares to answer any questions the examiner may have about the application.

  • Requests and Responses

    In a typical FINRA membership application, the examiner will issue an initial request for supplementary information within 30 days of application filing. While FINRA grants the applicant 60 days to respond to the initial request and 30 days to respond to subsequent requests, FirstMark works with the appliant to gather and respond to these requests in far shorter time frames. This is a key element in gaining approval in less than the maximum 180 days afforded to FINRA by its rules.

  • FINRA Membership Interview

    After FINRA has enough information to begin to form an opinion on the application, it will schedule a Membership Interview. NASD Rule 1013(b) provides that FINRA must conduct a membership interview before it serves a decision on the applicant. The FINRA Membership Interview is conducted at the FINRA District Office in the jurisdiction where the applicant’s main office will be located. FINRA must issue a decision within 30 days of the conclusion of the membership interview or, if FINRA requests additional information at or after the membership interview, within 30 days after the filing of additional information or documents. FirstMark prepares the principals of the applicant for the FINRA membership interview, and will also attend.

  • FINRA Membership Decision

    After all information has been submitted and reviewed, and after FINRA has completed the membership interview, it will issue a decision on the application. FINRA may either approve, approve with restrictions, or deny the application. The reality is that a FINRA membership application is denied in only a very small percentage of instances. However, having expert assistance in filing the application can make all the difference in terms of timing and avoiding unnecessary delays.

  • Ongoing Support

    FirstMark is there to continue supporting the new FINRA member long after the conclusion of the FINRA membership application process. By demonstrating outstanding commitment to the applicant’s goals, FirstMark experiences long-lasting, productive partnerships with its FINRA membership application clients.

FINRA MEMBERSHIP REQUIREMENTS

The FINRA new member application process is a journey. Many want to know how quickly a FINRA membership application will be approved. The answer is that, per its rules, FINRA has up to 180 days from the date of filing to issue a decision on a new member application. Many want to move faster than that, and seek approval in a shorter time period. While a faster approval of a FINRA membership application is possible, much depends on the quality of the application and the complexity of the proposed business. An approval of a limited business broker-dealer may occur in 3-4 months rather than 6. The FINRA membership application must clearly detail (with supporting evidence) how the applicant meets each of the 14 standards for admission as outlined in NASD Rule 1014. Only after FINRA makes that determination will it issue a decision letter. FINRA requires extensive detail and supporting documentation in order to reach its determination that the applicant meets each of the 14 standards for admission. By its nature, a FINRA membership application filing involves quite a bit of preparation and information gathering – often 30 – 45 days. All information is filed with FINRA through its Gateway system.

FINRA Membership Application

FINRA Membership Application Process

A FINRA membership application is a complex process that requires significant planning. FirstMark works with the applicant to provide strategic advice regarding the application process, proposed business lines, supervisory personnel, capital requirements and structure. FirstMark prepares all required documents, including the FINRA-required business plan, written supervisory and compliance procedures, anti-money laundering compliance program and procedures, business continuity plan, identity theft prevention program, registration and licensing documents and disclosures, and many other items. FirstMark’s goal is to make the process as easy as possible while achieving the goals desired by the applicant.