FINRA Streamlines Bulk Account Transfer Process

FINRA eliminated the requirement for firms to submit draft negative consent letters for staff review before effecting bulk account transfers.

In a Regulatory Notice, FINRA said the procedural change is intended to "reduc[e] unnecessary burdens" on firms, particularly when transfers are necessary due to "urgent business reasons [or] time constraints." FINRA also consolidated prior guidance to clarify that while affirmative customer consent is generally required, negative consent may be appropriate in limited bulk transfer situations, such as when a firm leaves a line of business or is acquired.

FINRA also detailed effective practices for these transfers to ensure compliance with high standards of commercial honor. FINRA recommended that firms generally provide customers with at least 30 days' notice and a clear description of the transfer's impact. Additionally, firms should provide clear opt-out procedures and are encouraged to waive transfer fees for customers who choose to move their accounts to a different provider rather than accept the negative consent transfer.

The procedural change will take effect on April 1, 2026.