Guidance for Governing Documents and Attestations to Evidence Ownership

Overview

Form CMA is organized by 14 standards for admission as set forth under Rule 1014(a) and specifies the documents and information required to support each standard. The items listed in this checklist are also organized by standard and focus on the standards and their related documentation and information that an applicant may inadvertently overlook when submitting the application. Firms should treat this checklist as a starting point for preparing Form CMA. Firms are advised to review the rules applicable to a CMA, including Rules 1014 and 1017, together with Form CMA. During the course of the review process, FINRA may request additional documents and information as necessary to render a decision on the application.

FINRA reminds firms that there are some timing considerations for submitting a CMA depending upon the contemplated change. For example, a member must file a CMA for approval of a change in ownership or control at least 30 days prior to such change. But notwithstanding this timing consideration and others—where a member or associated person has an unpaid arbitration award or unpaid settlement related to an arbitration at the time of filing the CMA—the member may not effect such change until the member has demonstrated in the application its ability to satisfy such obligation in accordance with Rule 1014 and IM-1014-1. FINRA reminds firms that responses and documentation in a foreign language will not be accepted and must be certified and translated to English, having converted all currencies to U.S. dollars. In addition, FINRA maintains firms’ confidentiality but will not accept redacted documents.

FINRA Compliance Tool Disclaimer

This optional tool is provided to assist member firms in fulfilling their regulatory obligations. This tool is provided as a starting point, and you must tailor this tool to reflect the size and needs of your firm. Using this tool does not guarantee compliance with or create any safe harbor with respect to FINRA rules, the federal securities laws or state laws, or other applicable federal or state regulatory requirements. This tool does not create any new legal or regulatory obligations for firms or other entities.

Updates

This tool was last reviewed and updated, as needed on June 27, 2024. This tool does not reflect any regulatory changes since that date. FINRA periodically reviews and update these tools. FINRA reminds member firms to stay apprised of new or amended laws, rules and regulations, and update their WSPs and compliance programs on an ongoing basis.

Member firms seeking additional guidance on certain regulatory obligations should review the Broker-Dealer Registration Topic Page and other relevant FINRA Topic Pages.

Staff Contact(s)

FINRA's Office of General Counsel (OGC) staff provides broker-dealers, attorneys, registered representatives, investors and other interested parties with interpretative guidance relating to FINRA’s rules. Please see Interpreting the Rules for more information.

OGC staff contacts:

Kosha Dalal and Sarah Kwak
1700 K Street, NW
Washington, DC 20006
(202) 728-8000

MAP staff contacts:

Jante Turner
(202) 728-8317

MAP Group
(212) 858-4000 (Option 5 – Membership Applications)