FINRA’s Continuation of Membership process (also known as a FINRA CMA filing) has earned the reputation with some as an onerous process. One of the criticisms of the FINRA CMA program was that the process for reviewing a FINRA CMA filing took too long. However, FINRA’s rules specify the maximum duration of a FINRA CMA filing – 180 days. And there are other time limits specified by the rules, such as the time that FINRA has to request additional information once it receives an application or a response to a subsequent question – usually 30 days. But let’s remember that there are often three sides to any story – their story, my story and the truth which lies somewhere in the middle.
The public criticism of the FINRA CMA program involved extended time frames (applications taking the full six months – or longer – to complete) and an overly complex process. But one frequent reason for delays in its processing of a FINRA CMA filing is that applicants do not provide the minimum required information, or that applicants do not pass the required qualification examinations in time. The truth is that both sides have a significant role in determining the duration of a FINRA CMA filing. In fact, applicants who used experienced professionals to guide them through the FINRA CMA filing process can avoid unnecessary delays.
FINRA has made significant changes to its program in recent years, streamlining the process and even creating an expedited review program for certain applications. It has created an online application program and made significant staffing commitments to help process CMA applications in a timely manner. FirstMark’s experience with the FINRA process is that when applications are thorough and complete, that FINRA staff is responsive and move very quickly.
When a broker-dealer is considering a FINRA CMA filing it is critically important that they have expert professional guidance from a FINRA CMA expert. Mitch Atkins, FINRA’s former South Region Senior Vice President, has over 21 years of experience dealing with NASD and FINRA CMA applications of all types. If you are considering a material change, use an expert who can help you shorten the duration of your FINRA CMA filing . Contact Mitch Atkins at FirstMark Regulatory Solutions by calling 561-948-6511.
