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Overview of Scenarios Described in FAQs 39-44

The following chart provides an overview of the scenarios described in FAQs 39-44, covering Form BR filings—initial and amendments—for FINRA and a jurisdiction, and the NYSE, as applicable. A firm that is registered with FINRA but not with the NYSE is hereinafter referred to as a “FINRA-only member firm.” If a firm is a FINRA/NYSE firm, the firm is reminded that the NYSE has not accepted the RSL designation, and the firm should carefully review applicable requirements when considering whether to close a location as a branch office with the NYSE.

In all cases, including when a branch office is closed, firms must also report an RSL as an Office of Employment Address (OEA) on an associated person’s Form U4 by responding “Yes” to the RSL Question within the required timeframes provided in Q15.6/A15.6 and maintain RSL information in the firm's internal records.

Form BR Filings—Initial and Amendment—for FINRA RSLs

Scenario

FINRA-Only Member

FINRA/NYSE Member

FINRA RSL located in a branch participating jurisdiction+ that does accept RSL*

Initial

  • No Form BR required

Initial

  • File an Initial Form BR
  • De-select FINRA check box
  • Leave NYSE check box pre-selected
  • De-select jurisdiction check box

 

Amendment

  • The branch office can be closed by submitting a Form BR Closing

Amendment

  • File a Form BR Amendment 
  • De-select FINRA check box
  • Leave NYSE check box pre-selected
  • De-select jurisdiction check box

 

FINRA RSL located in a branch participating jurisdiction+ that does not accept RSL*

Initial

  • File an Initial Form BR
  • De-select FINRA check box
  • Leave jurisdiction check box pre-selected

Initial

  • File an Initial Form BR
  • De-select FINRA check box
  • Leave NYSE check box pre-selected
  • Leave jurisdiction check box pre-selected

 

Amendment

  • File a Form BR Amendment
  • De-select FINRA check box
  • Leave jurisdiction check box pre-selected

Amendment

  • File a Form BR Amendment 
  • De-select FINRA check box
  • Leave NYSE check box pre-selected
  • Leave jurisdiction check box pre-selected

 

FINRA RSL located in a non-branch participating jurisdiction. + *

Initial

  • No Form BR required

Initial

  • File an Initial Form BR
  • De-select FINRA check box
  • Leave NYSE check box pre-selected
  • Leave jurisdiction check box de-selected

 

Amendment

  • The branch office can be closed by submitting a Form BR Closing

Amendment

  • File a Form BR Amendment 
  • De-select FINRA check box
  • Leave NYSE check box pre-selected
  • Leave jurisdiction check box de-selected

 

+ As used in this chart, a “branch participating jurisdiction” refers to a state jurisdiction that requires registration or “notice filing” of branch offices and a “non-branch participating jurisdiction” refers to a state jurisdiction that does not require registration or “notice filing” of branch offices.

* See SRO/Jurisdiction Fee and Setting Schedule – Web CRD.