On March 9, 2020, the Financial Industry Regulatory Authority, Inc. (FINRA) issued Regulatory Notice 20-08 to members, granting temporary relief from certain regulatory requirements and providing guidance on actions firms should take in light of the COVID-19 pandemic.
FINRA granted temporary relief in connection with the following requirements:
Deadline Extensions: FINRA stated that, upon request, it will consider extending deadlines for regulatory filings and responses to requests it issues in inquiries and investigations into members. Member firms that require extra time to respond to requests or make an upcoming filing are advised to contact their Risk Monitoring Analysts or the relevant FINRA department to seek such an extension.
- Remote/Telework and Emergency Relocations: FINRA acknowledged that registered persons may need to use remote offices or telework arrangements, which require alternative methods to reasonably supervise their activities. In addition, member firms are temporarily not required to submit branch office applications on Form BR when opening a temporary office location or space sharing arrangement. Nevertheless, if a firm relocates an office to an emergency location that is not registered as a branch office or regular non-branch location, it should use its best efforts to provide its Risk Monitoring Analyst with written notification.
- Form U4: FINRA has temporarily suspended the requirement that firms maintain updated office of employment address information on a registered person’s form U4 in the case of a relocation due to COVID-19.
FINRA also warned member firms about the increased Cyber Security risks associated with the COVID-19 pandemic and recommends that firms take the following cyber-safety measures:
- Ensure that virtual private networks (VPNs) and other remote access systems have been updated with all of the latest security patches.
- Confirm that system entitlements (access permissions) are current.
- Use multi-factor authentication for remote access to the firm’s systems.
- Use education and exercises promoting vigilance, employees of cyber risks.
FINRA Postpones In-Person Arbitration and Mediation Hearings
FINRA has also administratively postponed all in-person arbitration and mediation proceedings scheduled through May 31, 2020. Note that this postponement does not affect other case deadlines, which will continue to apply