Residential Supervisory Locations (RSLs)

Under Rule 3110.19, a “residential supervisory location” (or RSL) is generally defined as a private residence from which an associated person engages in supervisory functions, including those described in FINRA Rule 3110(f)(1)(D), (E), (F) and (G), and FINRA Rule 3110(f)(2)(B).  An RSL is non-branch location, which means that a firm does not need to register it as a branch office under Article IV, Section 8 of the FINRA By-Laws.  As a non-branch location, a firm is required to inspect an RSL on a regular periodic schedule in accordance with FINRA Rule 3110(c)(1)(C) and FINRA Rule 3110.13.  Starting on June 1, 2024, a firm may start using the RSL designation, subject to the terms set forth under Rule 3110.19. 

In general, to use the RSL designation, a firm and the associated person at each location must meet specified eligibility requirements and conditions.  Among other requirements, a firm must conduct and document a risk assessment, and provide a list of RSLs to FINRA on a periodic basis.  Rule 3110.19(d) requires a member firm that elects to designate any of its offices or locations as RSLs to provide FINRA with a current list of them by the 15th day of the month following each calendar quarter in the manner and format (e.g., through an electronic process or such other process) as FINRA may prescribe.

As member firms determine which offices or locations may be eligible for RSL designation, firms are reminded of their obligations to maintain updated Form U4 (Uniform Application for Securities Industry Registration or Transfer) information regarding the office of employment address for registered persons who temporarily relocated due to the pandemic and as applicable, to submit branch office applications on Form BR (Uniform Branch Office Registration Form) to register their branch offices.  While Regulatory Notice 20-08 (Notice 20-08 Relief) temporarily suspended these obligations due to the pandemic, the Notice 20-08 Relief ends on May 31, 2024.