FINRA provided guidance (see here and here) to address issues arising from temporary relief extended to firms in response to COVID-19 challenges.
The first FAQ addressed verifying "the accuracy and completeness of some of the information contained in the Form U4 within the 30-day period." FINRA explained that if verification of the information is not "feasible or practical within the 30-day period following the submission of the Form U4" then "firms should document which information could not be verified and the reasons (including the steps taken to verify the information) and should maintain an appropriate record." Further, FINRA advised firms to make "reasonable efforts" to verify such information by June 30, 2020, and, if necessary, to file amended forms thereafter.
In a separate FAQ, FINRA stated that "individuals who were designated to function as Operations Professionals under Rule 1220(b)(3)(B) prior to February 2, 2020 will be given until June 30, 2020 to pass the appropriate examination."
Originally published 18 May 2020
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