Frequently Asked Questions about Billing and Collections

General Billing/Collection Questions

Q1. What are the methods of making payments for FINRA invoices?

A1. The preferred method of payment is through E-Bill, which firms can access via the FINRA Gateway. Visit the E-Bill page for more information on making payments via E-Bill. E-Bill users also have access to AutoPay. AutoPay allows E-Bill users to set parameters to automatically pay invoices and fund their FINRA Flex-Funding Account. Visit the E-Bill User Guide for instructions to set up AutoPay.

The next best way to make payment to FINRA is via check. When making payments by check, include the invoice number with your payment.

Wire/ACH payments are also acceptable, but please remember to include the invoice number as the reference number, so we can properly apply your payment.

Q2. Will I receive a paper invoice from FINRA?

A2. FINRA's primary delivery method for invoices is electronic via E-Bill (with the exception of Dispute Resolution and Fines and Costs invoices).

Q3. Who do I call if I have questions?

Q4. If a firm received notice of an unpaid invoice, can they make payment with funds in the Flex-Funding Account?

A4. Yes, firms can reallocate funds currently in their Flex-Funding Account to pay an open invoice on E-Bill.

Q5. Where can I find more information on how to use E-Bill?

A5. Please see the E-Bill page.

Q6. How do I access E-Bill?

A6. E-Bill can be accessed through FINRA Gateway. Contact your firm's Super Account Administrator (SAA) for entitlement to E-Bill.

Q7. Where can I find more information on requesting a refund from our Flex-Funding Account?

A7. Please refer to the Flex-Funding Accounts Refunds Request page. Refund requests submitted through E-Bill will only be processed for approved firms. If your firm has filed a BDW, a refund will be processed 60 days after the BDW submission date.

Q8. Our firm is requesting a refund of CRD fees assessed in error. How do we request a refund?

A8. Please refer to the Refund Requests for Charges Assessed in Error page.

FINRA’s Audit Trail Reimbursement Process (CAT Cost Recovery Fees)

Q1. What fees are invoiced through FINRA’s Audit Trail Reimbursement process?

A1.  FINRA will invoice fees through the Audit Trail Reimbursement process to implement CAT cost recovery fees and assessments.  Specifically, FINRA has implemented two recovery initiatives through which FINRA will recoup its designated share of: (1) the prospective fees FINRA is required to pay towards funding the ongoing operations and maintenance of CAT; and (2) the historical costs FINRA was required to pay towards the creation and implementation of CAT. These amounts are assessed on member CAT Executing Brokers for transactions executed otherwise than on an exchange.

• Prospective Fees - Each member CAT Executing Broker will receive its first invoice from FINRA in October 2024, setting forth the fees calculated based on transactions in September 2024, and will receive a monthly invoice thereafter until a new subsequent Prospective CAT Cost Recovery Fee is in effect. 
• Historical Assessment - Each member CAT Executing Broker will receive its first invoice from FINRA in November 2024, setting forth the fees calculated based on transactions in October 2024, and will receive a monthly invoice thereafter until FINRA’s initial designated share of currently assessed historical CAT costs ($4,391,414) is recovered. 

Q2.  How do I access my invoice?

A2.  Invoices are available through E-Bill.

Q3.  Where can I find more details for my invoice?

A3.  Detailed trade files are available through E-Bill.

Q4.  Is there a de minimis fee where an invoice would not be produced?

A4.  Members will receive an invoice if there is any billable activity. However, if the total fee for a given month is less than $0.01, an invoice will be generated but will reflect a total fee of $0.00.

Q5.  Where can I find more information regarding FINRA’s Audit Trail Reimbursement process? 

A5.  Please refer to FINRA Rule 6897 for more information.

Q6.  Where can I find details on the amounts invoiced by FINRA through FINRA’s Audit Trail Reimbursement process?

A6. To provide transparency to the industry, FINRA will make publicly available the following:

Prospective Fees

• the total amount invoiced each month that the prospective fee is in effect,
• the total amount invoiced for the prospective fee for all months since its commencement, 
• the total amount that FINRA is invoiced each month by CAT LLC in connection with the related CAT fee, 
• the total amount that FINRA has been invoiced for the related CAT fee for all months since its commencement, and 
• the variance, both on a monthly and cumulative basis, between the amount invoiced by FINRA and the amount FINRA is invoiced for the related CAT fee.

Historical Assessment

• the total amount invoiced each month that the historical assessment is in effect, 
• the total amount invoiced for the historical assessment for all months since its commencement, and 
• the total costs remaining to be collected from members in aggregate for the relevant historical assessment. 

Please refer to  the Audit Trail Reimbursement Billing Data (ATRBI) page.

Central Registration Depository/Flex Funding (CRD)

Q1. Our firm submitted a payment for deposit into our Flex Funding Account; however, it is not reflected on E-Bill. Where did the funds go?

A1. Payments received by FINRA before 2 p.m. ET, should be available in E-Bill the next business day. If the deposit is received after 2 p.m. ET, the deposit should be available in E-Bill in two business days.

Q2. How do I request a refund of duplicate registration fees and other fees charged to our Flex-Funding Account?

A2. Please refer to the Refund Requests for Charges Assessed in Error page.

Corporate Actions

Q1. Can I get a fee waiver?

A1. Please send an email to [email protected] with your request, and FINRA Finance Department will forward it to the Corporate Action Department for review.

Q2. Where can I get more information on the fees assessed for my filing?

A2. Contact the Corporate Actions team at (866) 776-0800 for all fee-related inquiries.

Dispute Resolution

Q1. Where can I find out more information on Dispute Resolution services?

A1. Please consult the Dispute Resolution services page.

Q2. I show that my invoice has a credit balance. When should I expect to receive the refund check?

A2. If there are no additional fees due, a refund will be issued approximately 45-60 days after FINRA closes your case.

Q3. I am expecting a refund check. Does the refund check get sent to the attorney or the party listed in the case?

A3. Refunds are issued approximately 45-60 days after FINRA closes your case. Refunds are made payable to the named parties but are mailed to the counsel of record, if applicable.

Q4. I do not believe a fee that I was assessed is accurate. How can I get the error corrected?

A4. You will need to contact your case administrator. The case administrator assesses the fees in the case and would be responsible for any adjustments. Case administrator contact information is provided on your invoice. If you are not able to contact your case administrator, please reach out to the FINRA Finance Department at 240-386-5992 or by email at [email protected].

Q5. How can I get a copy of older invoices for an arbitration case?

A5. If you are the individual that was listed in the case, or an attorney that represented a party in the case, you can email [email protected] or call (240) 386-5992 to obtain a copy of the invoice. If you send an email, please include the case ID number and the firm/individual that the invoice was billed to.

Q6. The address that was listed on my invoice is incorrect. How do I update it?

A6. Please email [email protected] the new address as well as the party name and case ID number.

Q7. How can I start a payment plan or apply for a financial hardship?

A7. Please contact the FINRA Finance Department at (240) 386-5992 or by email at [email protected] to review your options. Those who are unable to pay the balance in full may request a payment plan. Additionally, investors and associated persons may request a financial hardship waiver. Please indicate which option you are requesting and reference the customer number in the email.

Fines and Costs

Q1. I have to pay a fine to FINRA. Where do I send my payment?

A2. Fines can be paid via check and Wire/ACH. Please remember to reference the complaint number and invoice number (if applicable) so we can properly apply your payment.

Q2. Can I pay my fine with a credit card?

A2. Fines under $50,000 can be paid with a credit or debit card. Please email [email protected] to receive an approved Authorization Form.

Q3. I elected to pay my fine via the installment payment plan. Where can I find more information on the payment plan?

A3. For more information on the terms of the installment payment plan, please email [email protected]

Fixed Income Regulation Fee/Trade Reporting and Compliance Engine (TRACE)

Q1. Where do I get the trade detail for my TRACE invoice?

A1. The TRACE trade detail is available in E-Bill. You can access the trade detail by clicking on the link besides the invoice.

Q2. Who do I contact for the user ID detail for the TRACE Invoice?

A2. Contact Jackie Busch at (240) 386-4734 or by email: [email protected].

Q3. Do firms need to call and discontinue their TRACE service even though they are terminated?

A3. Yes, firms must call FINRA Operations at (866) 776-0800. Before termination is complete, firms must complete the electronic order to discontinue service.

GASB (Governmental Accounting Standards Board)

Q1. What are GASB Fees?

A1. The GASB Accounting Support Fee is collected quarterly from member firms that report trades to the Municipal Securities Rulemaking Board (MSRB).

Q2. How are the GASB fees calculated?

A2. Each member firm's assessment is based on the member firm's portion of the total par value of municipal securities transactions reported by all FINRA member firms to the MSRB during the previous quarter.

Member Regulatory Fee (Annual Assessment)

Q1. What is the Annual Assessment Invoice?

A1. The Annual Assessment Invoice is your Annual FINRA Membership Fee (this is also known as the Member Regulatory Fee).

Q2. What is included on the Annual Assessment Invoice?

A2. The Annual Assessment Invoice is based on a firm's previous years quarterly FOCUS Reports, which is the basis for calculating the Gross Income Assessment Fee (GIA Fee), and the number of registered representatives on record for the firm as of Dec. 31 the previous year (PA Fee).

Q3. How is the GIA calculated?

A3. The GIA currently is assessed through a seven-tiered rate structure with a minimum GIA of $1,200. The assessable annual GIA is the greater of (1) the amount that would be the GIA based on the existing rate structure (current year GIA) or (2) a three-year average of the GIA to be calculated by adding the current-year GIA plus the GIA assessed on the firm over the previous two calendar years, divided by three. There are several factors to be taken into consideration for the GIA, and more specific information can be found in Regulatory Notice 09-56.

Q4. Why is my firm’s Annual Assessment Invoice higher than usual/normal?

A4. FINRA is implementing a proportional increase to fees it relies on to substantially fund its regulatory mission in a manner that preserves equitable fee allocation across FINRA members. Specifically, FINRA is implementing increases to the Gross Income Assessment (GIA), Trading Activity Fee (TAF), and Personnel Assessment (PA) phased in over a three-year period, beginning in 2022. Please refer to the FINRA Fee Increase Schedule for additional information.

Q5. If a firm is going to amend its FOCUS report or has filed an amended FOCUS report, does the firm need to inform FINRA Finance before it pays its invoice, or should the firm wait for the adjusted invoice?

A5. Firms should call Chantel Wright (240) 386-5392 or email [email protected] if amendments affect the revenue totals and if their gross FOCUS revenue is greater than $1 million.

Q6. If a firm files a Form BDW after paying its Member Regulatory Fee, will the firm be entitled to a refund?

A6. Firms will be eligible for a prorated refund of the GIA; however, if the BDW is filed in the fourth quarter, a refund will not be available. Personnel Assessments are neither refunded nor prorated.

Q7. How is the Personnel Assessment determined?

A7. The Personnel Assessment is based on the firm's number of registered representatives as of Dec. 31 of the previous year under a tiered rate structure. The fee structure is as follows:

If you have questions regarding the number of registered representatives used in calculating your firm's PA assessment, please contact Danny Mi at (240) 386-4764.

Q8. If a firm terminates any of its personnel prior to year-end, will the firm receive a Personnel Assessment refund?

A8. No. Personnel Assessments are neither refunded nor prorated.

Q9. Will firms be billed for additional Personnel Assessment if they hire new personnel during the year?

A9. No. As noted above the Personnel Assessment is based solely on the number of registered representatives as of Dec. 31 of the preceding year.

Q10. Where can firms view their Annual Assessment Invoice?

A10. The Annual Assessment Invoice is available through E-Bill, which you can access via FINRA Gateway.

Q11. Can firms pay their invoices through the Flex Funding Account?

A11. Yes, firms can reallocate funds via E-Bill.

Q12. When is the payment due?

A12. Payment is due upon the receipt of the invoice.

Q13. Can we pay the Annual Assessment Invoice in installments?

A13. Firms can pay the entire invoice upon the receipt of the invoice. If a firm chooses, payments can be made in 4 installments as follows:

• 25% due by April 30
• 25% due June 1
• 25% due Sept. 1
• 25% due Dec. 1

To use the installment payment plan, the first installment payment must be received by April 30. Payment in full is required after April 30.

Q14. Is the GIA the same fee as the Annual Renewals Statement received and paid in December each year?

A14. No, the GIA is not the CRD renewal statement that firms pay at the end of the year.

• The GIA for each firm is based on the revenue the firm filed on its FOCUS Reports in the previous year and is paid directly to FINRA (Membership Fee). Read more information on the GIA on FINRA's website.
• The CRD Renewal Statement consists of fees based on the states in which firms have personnel. FINRA collects these fees on behalf of the states and passes the fees directly to the states.

Over-The-Counter Reporting Facility (ORF)

Q1. Where can I find out more information on ORF?

A1. Please consult the ORF page.

Q2. Where do I get the trade detail for my ORF invoice?

A2. The ORF trade detail is available in E-Bill. You can access the trade detail by clicking on the link beside the invoice.

Q3. Who do I contact for the user ID detail for the ORF Invoice?

A3. Contact FINRA Operations at (866) 776-0800.

Q4. How are ORF fees calculated?

A4. Please consult the Rule 7710 OTC Reporting Facility page for more information.

Public Offerings

Q1. A wire was sent for our filing however the Public Offerings system shows a balance due?

A1. Contact the FINRA Accounts Receivable Department at (240) 386-5910 or email [email protected] to confirm receipt of payment.

Regulatory T Filings (Reg-T)

Q1. General Information

A1. The Federal Reserve Board's Regulation T and SEC Rule 15c3-3 provide for the possibility of extensions of credit by broker-dealers to investors when they have not promptly paid for a securities transaction.
 
Specifically, Regulation T gives an investor a maximum of four business days to pay for securities purchased in a cash or margin account. If payment due exceeds $1,000 and is not received by the end of this time period, the broker-dealer must either liquidate the position or apply for and receive an extension from its designated examining authority, such as FINRA.
 
SEC Rule 15c3-3 pertains to a customer's obligations when securities are sold, other than short sales. The rule requires that if a security sold long has not been delivered within 10 business days after the settlement date, the broker-dealer must either buy the customer in, or apply for and receive an extension from its designated examining authority.
 
Q2. How do I submit fillings?

A2. Firms must file Regulation T and SEC Rule 15c3-3 extension of time requests via FINRA's Regulatory Extension (REX) system (formerly known as the Reg T application). See Regulatory Notice 10-28 for more information.

Q3. How can I obtain the Regulation Extension Form?

A3. Sign in to the FINRA Gateway to access the REX form.

Q4. Where can I find out more information on Regulation T Filings?

A4. Please consult the Regulation T Filing page.

Regulatory Transaction Fee/Section 3 (RGFEE)

Q1. General Information

A1. This section is designed to help FINRA member firms understand the process FINRA uses to calculate the Regulatory Transaction Fee. As provided under Section 3 of Schedule A to the FINRA By-Laws, FINRA assesses member firms with the regulatory transaction fee, with the amount determined periodically in accordance with Section 31 of the Securities Exchange Act. 

The basis for the Regulatory Transaction Fee is trade reports provided to FINRA, by firms, through the Over-the-Counter Reporting Facility (ORF), the Alternative Display Facility (ADF), the FINRA/NASDAQ Trade Reporting Facility (NQTRF), and the FINRA/NYSE Trade Reporting Facility (NYTRF). Activity for each trade reporting facility is broken out onto a separate line on the invoice. The invoice line item for each trade reporting facility includes fees for trades for the month net of trade reversals and step-out transactions.

Trade reports are accumulated and processed monthly for billing. In cases where a reported trade is amended, FINRA uses the final state of the trade as the basis for determining whether the trade should be included, or excluded, from the Regulatory Transaction Fee calculations. For example, if a trade has been corrected three times during a month, the state of the trade following the third, and final, correction will be used as the basis for the calculation for that month.

Q2. Which date drives the calculations?

A2. FINRA uses the Trade Report Date (i.e., the date the trade is reported to the FINRA facility) for determining the appropriate billing period and rate (which is the same rate as that determined by the SEC for calculating FINRA's Section 31 fees).

Q3. What trade amounts are used for the calculations?

A3. The Contract Value (Entered Price times Entered Volume) is multiplied by the applicable rate to determine the fee.

Q4. Which firm is billed?

A4. Generally, the clearing firm reported on the sell-side of the transaction will be charged for the Regulatory Transaction Fee. 

If the clearing firm that is determined to be on the sell-side of the trade is not an active FINRA member, the Regulatory Transaction Fee will be charged to the clearing firm on the buy-side. If neither the sell-side clearing firm nor the buy-side clearing firm is an active FINRA member, the Regulatory Transaction Fee will be charged to the firm associated with the MPID on the sell-side of the trade. If that firm is not an active FINRA member, the Regulatory Transaction Fee will be charged to the firm associated with the MPID on the buy-side of the trade.

Q5. Which trades are included?

• Trades marked by the reporting firm as "tape-reported" (i.e., Client-provided Publish Flag of ‘Y'-Yes) that have not been cancelled
• Clearing-Only Trades that have not been cancelled and are in the following categories only:
  • Options exercises
  • Away from the market trades
  • Position transfers

Q6. Which trades in equity securities are excluded from the Regulatory Transaction Fee calculations?

A6. Reportable trades in equity issues not subject to prompt last sale reporting (currently only applies to 144A securities)

Q7. How are reversals reflected in the calculations?

A7. The contract values for trade reversals reported in the month are calculated in the same way as regular trades. These are then subtracted from the aggregate contract value.

Q8. How are Step-outs reflected in the calculations?

A8. Fees are transferred on trade reports marked as "Step-out with fees" only if:

• both the reporting clearing number and the contra clearing number are active FINRA members; and
• the Reporting Party is on the Buy-side of the trade report and the Reporting Obligation is "Yes." 

The contract values for step-out transactions reported in the month are calculated in the same way as regular trades and result in a credit of the fee to the reporting party and a charge to the contra party. These are then included in the aggregate contract value.

Q9. Where can I find out more information on RGFEE?

A9. Please consult Regulatory Notice 08-72.

Q10. Where can I find more details for my invoice?

A10. The RGFEE invoice and trade details are available through E-Bill. Please refer to Regulatory Notice 08-72 for more information.

Trading Activity Fee (TAF)

Q1. Where can I find more information regarding TAF?

A1. Please consult the Trading Activity Fee page.

Q2. Why are my firm’s TAF fees higher than usual/normal?

A2. FINRA is implementing a proportional increase to fees it relies on to substantially fund its regulatory mission in a manner that preserves equitable fee allocation across FINRA members. Specifically, FINRA is implementing increases to the Gross Income Assessment (GIA), Trading Activity Fee (TAF), and Personnel Assessment (PA) phased in over a three-year period beginning in 2022. Please consult the FINRA Fee Increase Schedule for additional information.

Q3. When are TAF submission and payment due? 

A3. TAF forms are to be filed no later than the 10th business day of each month for the previous month’s activity. Payment is due upon receipt and is to be submitted along with the form, or through E-Bill the next day when the invoice has been generated. 

Q4. How do I request to amend a TAF form? 

A4. Email [email protected] to request an amendment along with the TAF account number, activity month, and the reason the TAF submission was reported incorrectly. 

Q5. If my firm believes it has overpaid the TAF fees, can we request a refund of the overpayment?

A5. If a firm believes that it has overpaid its TAF, the firm should promptly notify FINRA’s Finance Dept at [email protected]. To be eligible to receive a refund of an overpayment, a claim for a refund should be presented to FINRA’s Finance Dept for review in writing within 12 months of the date of the overpayment for review. FINRA may elect to waive the 12-month limitation. This provision does not limit FINRA’s authority to take action against a firm for noncompliance with FINRA rules and By-Laws or limit FINRA’s authority to assess and collect underpayments by a firm of the Trading Activity Fee.

Q6. Where can I find more information about the TAF online filing and payment process? 

A5. Please see the FINRA Trading Activity Fee (TAF) Filing - TAF Online Filing Process page. 

Questions

If you have additional questions regarding FINRA billing or collections, please contact the FINRA Accounts Receivable Department at (240) 386-5910 or Amanda Rath via email [email protected] or by phone at (240) 386-6637.