Rule 4111 Compliance Tool Glossary
FINRA Rule 4111(b) requires the Department of Member Supervision (Department) to calculate annually a member firm’s "Preliminary Identification Metrics" to determine whether the firm meets the "Preliminary Criteria for Identification."1 A key driver of that is whether a member firm’s Preliminary Identification Metrics meet quantitative, risk-based "Preliminary Identification Metrics Thresholds."2 The date, each calendar year, as of which the Department calculates the Preliminary Identification Metrics to determine if the member firm meets the Preliminary Criteria for Identification is the "Evaluation Date."3 For more information, see Rule 4111 and Regulatory Notice 21-34.
The Rule 4111 Compliance Tool, which resides in the FINRA Gateway, provides reports of:
- the Annual Calculation of whether the member firm met the Preliminary Criteria for Identification, including its Preliminary Identification Metrics, as of the Evaluation Date for a given year; and
- Interim Calculations as of an Evaluation Date for that given year. The Interim Calculations are generated for informational purposes only; whether a member firm will meet the Preliminary Criteria for Identification as of the Evaluation Date in the Annual Calculation could change based on subsequent events.
Each year’s report of the Annual Calculation will be issued shortly after the Rule 4111 Annual Calculation is conducted for that year. Prior to each year’s report of the Annual Calculation, FINRA generally expects to issue three reports of Interim Calculations for that given year, at regular intervals.4
Access
To access the Rule 4111 Compliance Tool, each user requires an account for logging into FINRA Gateway, and must request the "Firm View Rule 4111 Compliance Tool" entitlement from their firm’s Super Account Administrator (SAA). The SAA grants entitlement for the tool in FINRA’s Account Management System, under the Registrations sub-section, in the CRD suite of entitlements. Each user at the firm who needs to access the Rule 4111 Compliance Tool must be granted access for the tool by their firm’s SAA.
The Rule 4111 Compliance Tool resides in the Reports section of the FINRA Gateway. Users who are not entitled to the tool will not see the tool.
Summary View Fields
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Report Date |
The “Report Date” field provides the date that FINRA issued the report of the Annual Calculation or Interim Calculation. The Rule 4111 Compliance Tool will provide, as they are issued, reports of: (1) the Annual Calculations of whether the member firm met the Preliminary Criteria for Identification, including its Preliminary Identification Metrics, as of the Evaluation Date for a given year; and (2) Interim Calculations as of an Evaluation date for that given year. Each year’s report of the Annual Calculation will be issued in July, shortly after the Rule 4111 annual calculation is conducted for that year. Prior to each year’s report of the Annual Calculation, FINRA expects to issue three reports of Interim Calculations for that given year. The first report of an Interim Calculation will be issued in June 2022; thereafter, reports of Interim Calculations will be issued three times a year in October, January and April. The reports of Interim Calculations will be generated for informational purposes only; whether a firm will meet the Preliminary Criteria for Identification in the Annual Calculation could change based on subsequent events. |
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Evaluation Date |
The “Evaluation Date” is the date, each calendar year, as of which the Department calculates the Preliminary Identification Metrics to determine if the member firm meets the Preliminary Criteria for Identification. The Evaluation Date will establish the date as of which all specified events that are reportable on the Uniform Registration Forms, or otherwise included in Rule 4111, would be included in the Annual Calculation of the Preliminary Criteria for Identification. |
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Meets Preliminary Criteria? Annual Calculation |
The “Meets Preliminary Criteria? Annual Calculation” field is used only for the reports of Annual Calculations of whether the member firm met the Preliminary Criteria for Identification as of the Evaluation Date. The reports of Annual Calculations are issued in July.
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Meets Preliminary Criteria? Interim Calculation |
The “Meets Preliminary Criteria? Interim Calculation” field is only for the Interim Calculations as of an Evaluation Date. The reports of Interim Calculations will be generated for informational purposes only; whether a member firm will meet the Preliminary Criteria for Identification in the Annual Calculation could change based on subsequent events.
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Firm Size Category |
The number in the “Firm Size Category” field (a number between 1 and 7) reflects the member firm’s Firm-Size Category for purposes of the Rule 4111 Preliminary Identification Metrics Thresholds. There are Preliminary Identification Metrics Thresholds for seven Firm-Size Categories.5 The seven Firm-Size Categories, which are set forth in Rule 4111(i)(11), are based on the number of “Registered Persons In-Scope”:6
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Metrics Calculations |
The “Metrics Calculations” field shows the total number of Preliminary Identification Metrics calculated. Since there are six Preliminary Identification Metrics, this field will always be populated with the number 6. The user can use the field’s drop-down functionality to obtain additional details about the Preliminary Identification Metrics calculations. |
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Events |
The “Events” field displays the sum of the Registered Person Adjudicated Events, Registered Person Pending Events, Registered Person Termination and Internal Review Events, Member Firm Adjudicated Events, Member Firm Pending Events, and Registered Persons Associated with Previously Expelled Firms that are counted in the member firm’s Preliminary Identification Metrics.7 The user can use the field’s drop-down functionality to obtain additional details about the Events. |
Metrics Calculations Fields
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Events Category |
The “Events Category” field displays the events applicable to the Preliminary Identification Metrics as defined in Rule 4111. There are six Events Categories: 8
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Thresholds |
The “Thresholds” field displays the Preliminary Identification Metric Threshold for the applicable Preliminary Identification Metric. Pursuant to Rule 4111(i)(11), there are 42 Preliminary Identification Metrics Thresholds:
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Firm’s Metrics |
The “Firm’s Metrics” field shows the applicable Preliminary Identification Metric calculation, displayed as a numeric value. Pursuant to Rule 4111(i)(10), each Preliminary Identification Metric is computed as follows:
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Meets or Exceeds Threshold |
The “Meets or Exceeds Threshold” field (which displays as either “yes” or “no”) indicates whether the applicable Preliminary Identification Metric is equal to or more than the corresponding Preliminary Identification Metric Threshold. |
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Number of Events (Numerator) |
The “Number of Events” field displays the number of “Registered Person and Member Firm Events”10 per event category. |
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Number of Registered Persons In-Scope (Denominator) |
The “Number of Registered Representatives” field displays the total number of Registered Persons In-Scope.11 |
Events Fields
Term | Description |
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Report Date |
The "Report Date" field provides the date that FINRA issued the report of the Annual Calculation or Interim Calculation. The Rule 4111 Compliance Tool will provide, as they are issued, reports of: (1) the Annual Calculations of whether the member firm met the Preliminary Criteria for Identification, including its Preliminary Identification Metrics, as of the Evaluation Date for a given year; and (2) Interim Calculations as of an Evaluation date for that given year. Each year’s report of the Annual Calculation will be issued in July, shortly after the Rule 4111 annual calculation is conducted for that year. Prior to each year’s report of the Annual Calculation, FINRA expects to issue three reports of Interim Calculations for that given year. The first report of an Interim Calculation will be issued in June 2022; thereafter, reports of Interim Calculations will be issued three times a year in October, January and April. The reports of Interim Calculations will be generated for informational purposes only; whether a firm will meet the Preliminary Criteria for Identification in the Annual Calculation could change based on subsequent events. |
Evaluation Date |
The “Evaluation Date” is the date, each calendar year, as of which the Department calculates the Preliminary Identification Metrics to determine if the member firm meets the Preliminary Criteria for Identification. The Evaluation Date will establish the date as of which all specified events that are reportable on the Uniform Registration Forms, or otherwise included in Rule 4111, would be included in the annual calculation of the Preliminary Criteria for Identification. |
Firm CRD Number |
Broker-Dealer CRD # for the firm responsible for the submission. |
Registered Person or Registered Firm Event Category |
The categorization of the event:
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Individual CRD Number |
The Registered Representative’s individual CRD unique identifier |
Individual First Name |
Registered Representative first name on record |
Individual Last Name |
Registered Representative last name on record |
Disclosure Type |
The disclosure categories reported:
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Disclosure Occurrence Number or Firm Arbitration Case Number |
The unique identifier of the event, as tracked in FINRA systems. |
Export Details Data
The Export button for the 4111 Compliance Tool allows users to extract data from the tool. Choose to download to a single file or multiple files according to how much data you need to download at one time.
Information about the Export tool is available HERE.
Users should refer to the description of the terms above that describe the content and structure of the download files.
Endnotes
1Rule 4111(i)(10) (definition of “Preliminary Identification Metrics”); Rule 4111(i)(9) (definition of “Preliminary Criteria for Identification”).
2Rule 4111(i)(11) (definition of “Preliminary Identification Metrics Thresholds”).
3Rule 4111(i)(5) (definition of “Evaluation Date”).
4Prior to the Annual Calculation of whether the member firm met the Preliminary Criteria for Identification as of the June 1, 2022 Evaluation Date, however, FINRA will issue only one report of an Interim Calculation.
5Rule 4111(i)(11).
6Rule 4111(i)(13) (definition of “Registered Persons In-Scope”).
7Rule 4111(i)(4) (definition of the “Disclosure Event and Expelled Firm Association Categories”); Rule 4111(i)(10) (definition of “Preliminary Identification Metrics”).
8Rule 4111(i)(4).
9Rule 4111(i)(6) (definition of “Evaluation Period”).
10Rule 4111(i)(12) (definition of “Registered Person and Member Firm Events”).
11Rule 4111(i)(13).