Cooler air, fallen leaves and the start of the holiday frenzy are all sure-tell signs that another year is wrapping up. Alongside the end-of-the year countdown comes the time for broker-dealers and investment advisors to pay close attention to their 2022 FINRA Renewal Programs. If you want to avoid paying late fees this year, here are some dates that should be marked on your calendar.
Renewal fees are provided through two statements:
- The Preliminary Statement reflects registration information as of mid-November.
- The Final Statement reflects registration information as of January 1.
Preliminary Statement Period
Preliminary Statements are generated in mid-November. They reflect currently approved registrations that have not been terminated, including post-dated filings submitted before the statement is generated. Below are some important deadlines to keep in mind when it comes to this statement period.
ASAP: Review and Prepare for the 2022 Renewal Program.
- Download important renewal dates to your calendar.
- Take note of changes on the CRD/IARD Availability page.
- Confirm that the information for the Renewal Contact in FINRA Gateway is current.
- Enable email alerts about the Renewal Program in E-Bill.
- Review firm, branch and individual registrations to ensure registrations are renewed.
NOVEMBER 8: Retrieve the Preliminary Statement in E-Bill.
Preliminary Statements are available in E-Bill beginning November 8, 2021. Many firms find it convenient to submit or schedule their payment while logged in to E-Bill to retrieve the statement. Preliminary Statement reports are also available in CRD/IARD. Be sure to save or print these reports before Final Statements are generated as they cannot be recreated once the Final Statement is created.
DECEMBER 13: Ensure Full Payment is Available in Renewal or Flex-Funding Account
By December 13, FINRA-registered firms should ensure payment is received and posted to your account. Money can be deposited directly into your firm’s Renewal Account, or firms may rely on FINRA to transfer the money from your firm’s Flex-Funding Account beginning December 14, 2020. In order to take advantage of this transfer, the complete amount due for renewals must be available in your firm’s Flex-Funding account. Firms must pay the entire amount assessed on the Preliminary Statement. Failure to remit full payment of their Preliminary Statement to FINRA by December 13, 2021, may cause FINRA-registered firms to be subject to a late fee.
DECEMBER 23: Mass Transfer Moratorium Begins
A mass transfer is used to systematically transfer individuals and branch offices from one firm to another firm as a result of a merger, acquisition, succession or consolidation. Firms that will be requesting mass transfers must do so by December 1, 2021. There will be a moratorium on mass transfer processing from Dec. 23, 2021, through Jan. 2, 2022.
DECEMBER 26: Submit Filings and Payments Before the 2021 Deadline at 6 pm ET.
The CRD/IARD system shuts down for the year at 6 pm on December 26, 2021. Firms should ensure that they perform the following activities before the shutdown occurs:
- Submit/terminate registration filings. This includes terminating any registrations that firms do not want to renew for 2022.
- Finalize any E-Bill renewal payments or transactions. Firms that missed the payment deadline must ensure that renewal funds are posted by this date. At 6:00 pm ET, any unpaid Preliminary Statement will result in jurisdictions automatically terminating registrations for failing to renew (which will result in the inability to conduct business in these jurisdictions effective January 1).
- Print and/or save renewal reports in CRD/IARD. On January 2, Preliminary Statement reports will be replaced with Final Statement reports.
- Several CRD/IARD system outages occur during the Renewal Program. See the CRD/IARD Availability page for details.
Final Statement Period
Final Statements are made available in January. They display the registrations that were renewed for January 1 and any amount owed by the firm. If a firm overpaid the amount owed for the Final Statement, the overpayment was transferred to the firm’s Flex-Funding account.
JANUARY 2: Retrieve and Schedule Payment for the Final Statement in E-Bill.
Final Statements are available in E-Bill on January 2, 2022. Preliminary Statement reports are replaced with Final Statement reports in CRD/IARD. Many firms find it convenient to schedule any required payment while logged in to E-Bill to retrieve the statement. If additional payment is not required, the Final Statement will reflect “Paid in Full.”
JANUARY 28: Ensure Discrepancies are Reported or Balance is Paid.
Firms must submit any amount owed on the Final Statement to FINRA by this day. Money can be deposited directly into the Renewal Account, or firms can rely on FINRA to transfer funds from the firm’s Flex-Funding Account beginning January 22, 2021. In order to take advantage of this transfer, the complete amount due for renewals must be available in your firm’s Flex-Funding account. See the Renewal Payment Options page for more information. January 28, 2022, is also the deadline for firms to report in writing to FINRA any discrepancies found on the Final Statement.
See the following checklist for similar dates regarding the 2022 IARD Renewal Program for Investment Advisors.