FINRA Alerts Member Firms of Form BR Functionality Enhancements for Initial Form BR Submissions and Updated Residential Supervisory Location (RSL) FAQs

July 18, 2024

FINRA has implemented Form BR (Uniform Branch Office Registration Form) functionality enhancements for initial Form BR submissions that allow firms to de-select FINRA when establishing a new location designated as an RSL that needs to be registered or notice filed with a jurisdiction, the New York Stock Exchange (NYSE), or both, as a branch office. Further information on these functionality enhancements and how firms should complete an initial Form BR is available in the Frequently Asked Questions about Residential Supervisory Locations (RSLs).  

FINRA is currently developing related functionality enhancements that will allow firms to amend Form BR to account for RSL designations and will announce when these are implemented. Until such functionality enhancements are developed, firms are advised not to amend Form BR to account for the RSL designation and, as noted in the June 18, 2024 Alert, not to close/withdraw Form BR to account for the RSL designation in any jurisdiction or with any SRO that has branch office registration/notice filing requirements. Form BR can be amended in the usual manner for reasons unrelated to the RSL designation. The updated FAQs include more information.

FINRA continues to work to amend the Form U4 to add an “RSL Question” that will become the means by which member firms will comply with the reporting requirement under FINRA Rule 3110.19(d) (Obligation to Provide List of RSLs to FINRA). Until such functionality is available, member firms should maintain an internal list of all RSLs. FINRA will provide updated guidance in the near future.