ARTICLE
18 September 2018

FINRA Updates Process For Submitting Certain Requests For Extensions

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FINRA will update the Regulatory Extension ("REX") system to amend the process for soliciting extensions of time required under certain parts of Exchange Act Rule 15c3-3 ("Customer Protection Rule")...
United States Finance and Banking

FINRA will update the Regulatory Extension ("REX") system to amend the process for soliciting extensions of time required under certain parts of Exchange Act Rule 15c3-3 ("Customer Protection Rule") and extensions of credit by brokers and dealers under Regulation T.

Effective December 3, 2018, FINRA will update the REX system to (i) allow firms to submit Exchange Act Rule 15c3-3(d)(4) extensions of time requests in a batch file process, (ii) enhance the process by which firms request extensions of time under FINRA Rule 4230(a) and Exchange Act Rule 15c3-3(d), (m) and (h), and file the reports required under FINRA Rule 4230(b). From February 25, 2019, firms will not be mandated to submit a customer's complete social security or tax identification number and instead will have to provide the last four digits of such a number when asking for extensions of time.

Additionally, FINRA updated validation identifiers and validation criteria used in connection with Regulation T extensions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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