Reminder: FINRA Entitlement Certification Due by July 19, 2021

Foley Hoag LLP

Foley Hoag LLP

The 2021 FINRA Entitlement Certification period for broker-dealers, funding portals, investment advisers and US-based regulators that participate in the FINRA Entitlement program commenced on April 19, 2021 and ends on July 19, 2021. FINRA recommends that every organization perform periodic system access reviews to confirm that individuals have the appropriate level of entitlement required to perform their job responsibilities or remove access if no longer needed. In addition to this recommendation, FINRA requires Super Account Administrators (SAAs) of firms with other user and/or administrator accounts to complete the Entitlement Certification. These SAAs must certify that a review of access to systems on the FINRA Entitlement platform for all users and administrators within their organization has been completed.

Failure to certify by the July 19, 2021 deadline will result in the following actions:

  • The capability to create, edit and clone accounts will be disabled for all administrators within the organization after the certification due date and will remain disabled until the SAA completes the certification process.
  • Action by the appropriate regulator may be taken to ensure compliance with the process.
  • All accounts associated with the organization will be suspended until certification is completed.

Organizations that do not have other users and/or administrators in addition to their SAA will have the option to certify, but are not required to do so, unless the firm has access to the Consolidated Audit Trail (CAT).

Detailed instructions on how to complete the certification are available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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