July 7, 2020

Volume X, Number 189

July 07, 2020

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July 06, 2020

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The Financial Industry Regulatory Authority (FINRA) has updated its FAQs regarding coronavirus-related regulatory relief to address:

  • situations in which a member firm is unable, as required by FINRA Rule 3110(e), to verify some of the information in an initial or transfer Form U4 due to the COVID-19 outbreak;
  • the extension of expiring qualification examination windows until June 30, 2020, including for individuals who were designated to function as Operations Professionals under Rule 1220(b)(3)(B) or as principals under Rule 1210.04, in either case, prior to February 2, 2020 and who, under Rule 1220(b)(3)(B) or Rule 1210.04, respectively, otherwise would have had 120 days to pass the appropriate qualification examination;
  • the extension of deadlines for Rule 3120 reports until June 30, 2020 for member firms with reports that would otherwise be due between March 1 and June 1, 2020;
  • the extension of deadlines for Rule 3130 certifications until June 30, 2020 for member firms with certifications that would otherwise be due between March 1 and June 1, 2020 (and CCO meetings, as required as a condition for those certifications, can be conducted virtually); and
  • the extension, until June 30, 2020, of the currently-available temporary exemption from fingerprinting requirements, provided that certain notification requirements are met (see the full order here).

Note that FINRA also has emphasized that member firms must document their reliance on any temporary relief provided by FINRA during the COVID-19 pandemic.

The FINRA FAQs are available here.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume X, Number 150


About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

Michael T. Foley, Katten, Lawyer, Finance, FINRA, Chicago
Special Counsel

Michael Foley represents broker-dealers, investment advisers and other financial services industry participants with respect to a broad spectrum of legal and regulatory matters arising under the federal securities laws.

Michael has nearly 20 years of experience in private practice and in-house at both a large, full-service broker-dealer and at an online discount broker-dealer, advising broker-dealers and other financial institutions regarding compliance with the federal securities and commodities laws, and with the regulations of the US Securities and Exchange Commission, the US Commodity Futures Trading Commission and financial industry self-regulatory organizations. 

Gregory Uffner, Financial Services Attorney, Katten Law Firm

Gregory Uffner is an associate in the Financial Services practice. 

While in law school, Gregory was an associate editor for the Moot Court Board, a member of the Fordham Urban Law Journal and served as managing editor for the Fordham Sports Law Forum.

Elizabeth Organ Financial Markets and Funds Katten Muchin Rosenman New York, NY

Elizabeth Organ represents clients across the financial services industry, with a focus on regulatory compliance and advice. Liz's background positions her to provide valuable legal counsel on transactional and regulatory matters relating to commodities and derivatives, investment management, and cryptoassets and distributed ledger products.

Helping clients address complex regulatory and legal challenges

Liz assists clients with a range of financial services regulatory matters, collaborating with legal staff, business executives and regulators alike to pursue...