FINRA Reminds Members of New Off-Balance Sheet Reporting Obligations and Implementation Schedule (Regulatory Notice 16-11)

FINRA reminded member firms that proposed amendments to the instructions for the Derivatives and Other Off-Balance Sheet Items Schedule ("OBS") were approved by the SEC. The approved amendments expand the OBS's application to certain non-carrying/non-clearing firms that have significant amounts of off-balance sheet obligations. In its Notice, FINRA stated that firms that file for the first time must include in their initial OBSs disclosures of off-balance sheet information as of June 30, 2016, on or before August 2, 2016. Carrying or clearing firms that already were subject to OBS reporting requirements before the effective date of the amendments will continue to file on the requisite quarterly basis without interruption.