FINRA Highlights New SEC Electronic Filing Requirements for Broker-Dealers
FINRA summarized recent SEC rule amendments that establish new electronic filing, signature, and data-format requirements for broker-dealer annual reports and FOCUS filings. FINRA also highlighted upcoming compliance dates that affect members.
In an Information Notice, FINRA reviewed the following:
- Electronic Signatures. FINRA stated that the SEC now permits electronic signatures for all reports filed under SEA Rule 17a-5 ("Reports to be made by certain brokers and dealers"), including annual reports and FOCUS Reports, provided firms follow the required authentication procedures. FINRA noted that FOCUS Report Part II and Part IIA must now be signed by the principal executive officer or the principal financial officer.
- Oath or Affirmation. FINRA explained that the SEC eliminated the notarization requirement for the annual report’s Oath or Affirmation. FINRA emphasized that firms must retain the signed Oath or Affirmation for six years, with the first two years kept in an easily accessible place under SEA Rule 17a-4 ("Records to be preserved by certain exchange members, brokers and dealers").
- Electronic Submission to SEC via EDGAR. FINRA reported that, effective June 30, 2025, firms must file annual reports, supplemental reports under SEA Rule 17a-5, and Form 17-H electronically with the SEC through EDGAR as PDF filings, with paper submissions no longer accepted. FINRA advised firms to obtain EDGAR credentials by submitting Form ID and recommended applying early to avoid processing delays.
- Interactive Data File Requirements. FINRA reaffirmed that annual reports, supplemental reports, and Form 17-H will be required to be filed as Interactive Data Files under Regulation S-T.
Compliance Deadlines. FINRA stated that compliance dates depend on a firm’s minimum net capital as of December 31, 2025:
- June 30, 2027, for firms with minimum net capital of $250,000 or more.
- June 30, 2029, for firms with minimum net capital below $250,000.