2025 and First Quarter of 2026 Report Filing Due Dates

Summary

To assist members in their financial reporting obligations, FINRA is issuing this Notice to provide the due dates for Annual Report, Financial and Operational Combined Uniform Single (FOCUS), Form Custody, and supplemental FOCUS Report filings that are due in 2025 or the first quarter of 2026. FINRA reminds members that all such filings they submit to FINRA must be made electronically through FINRA Gateway. 

The due dates set forth in this Notice refer solely to the filings that are specified in the Notice and are required under SEA Rule 17a-5 or FINRA Rule 4524. These due dates take into account the federal holiday calendar as appropriate.

Questions regarding this Notice should be directed to your firm’s Risk Monitoring Analyst.

Background

Annual Report

Firms must submit their annual reports to FINRA in electronic form.¹ Pursuant to SEA Rule 17a-5(d)(6), firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. FINRA reminds members that the SEC has a process for electronic filing of annual reports, in lieu of filing in paper form, which the SEC simplified and updated in January 2017. ²  

In February 2021, the SEC issued an order³ that permits specified firms an additional 30 calendar days to file their annual reports as required pursuant to SEA Rule 17a-5(d), subject to certain conditions. The SEC’s order, in response to a request by FINRA, is designed to ease potential burdens that smaller members may face in obtaining audit services. Members that meet the conditions set forth in the SEC’s order and wish to avail themselves of the 30-day extension must provide notification to FINRA as described further in Regulatory Notice 21-05.⁴

Rule 17a-5(d)(6) requires firms that are members of the Securities Investor Protection Corporation (SIPC) to file the annual report with SIPC. Through an agreement between SIPC and FINRA,⁵ when a firm that is a SIPC member files an annual report through FINRA Gateway, this will also constitute filing with SIPC. Members may consult the SIPC website for further information.

Filings are due no later than 11:59 p.m. Eastern Time (ET) on the due dates listed in this Notice.

Annual Reports

FOCUS Reports

Firms must submit their FOCUS Reports electronically through the eFOCUS System available via FINRA Gateway. For information about completing the FOCUS Report, please see FINRA’s guidance on eFOCUS submission.

Monthly and Fifth⁶ FOCUS Part II/IIA Filings

Quarterly FOCUS Part II/IIA Filings

Annual Schedule I Filings

Form Custody

Firms are required to file Form Custody pursuant to SEA Rule 17a-5(a)(5).

Form Custody Filings

Supplemental Statement of Income (SSOI)

Firms must file the SSOI on a quarterly basis.⁷

SSOI Filings

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items (Form OBS) 

Unless subject to the de minimis exception, the Form OBS must be filed by (1) all member firms that self-clear their proprietary transactions or clear transactions for others or carry customer accounts; and (2) all other member firms that have, pursuant to SEA Rule 15c3-1, a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable items pursuant to the Form OBS.⁸ Any firm that is required to file the Form OBS must do so as of the last day of a reporting period within 22 business days of the end of each calendar quarter by using the eFOCUS system. A firm that claims the de minimis exception must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period. For more information on the Form OBS, including Frequently Asked Questions, please see the Derivatives and Other Off-Balance Sheet Items (OBS) page.

Form OBS Filings

Supplemental Inventory Schedule (SIS)

The SIS must be filed by a firm that is required to file FOCUS Report Part IIA or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, unless the firm has (1) a minimum dollar net capital or liquid capital requirement of less than $100,000; or (2) inventory positions consisting only of money market mutual funds.⁹ A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period.

FINRA reminds members that in 2021 FINRA revised¹⁰ the SIS so that members that are filers of FOCUS Report Part II are no longer required to file the SIS.   

SIS Filings

Supplemental Liquidity Schedule (SLS)

The SLS must be filed by each carrying member with $25 million or more in free credit balances, as defined under SEA Rule 15c3-3(a)(8), and by each member whose aggregate amount outstanding under repurchase agreements, securities loan contracts and bank loans is equal to or greater than $1 billion, as reported on the member’s most recently filed FOCUS Report, unless otherwise permitted by FINRA in writing.¹¹ The SLS must be completed as of the last business day of each month and filed within 24 business days after the end of the month. A member need not file the SLS for any period where the member does not meet the $25 million or $1 billion thresholds.

SLS Filings

FINRA Gateway and Entitlements

FINRA reminds firms that they must use their current FINRA entitlement user ID and password to access FINRA Gateway. Questions regarding access to FINRA Gateway should be directed to the firm’s Super Account Administrator (SAA). Questions regarding the filing of reports, the resetting of passwords or general technical concerns regarding system requirements should be directed to FINRA Business and Technology Support Services at (800) 321-6273.

Endnotes

1. See Regulatory Notice 11-46 (Annual Audit Reports: FINRA to Require Electronic Submission of Annual Audit Reports) (October 2011).

2. See Electronic Filing of Broker-Dealer Annual Reports on the SEC website; see also Regulatory Notice 17-07 (Updated SEC No-Action Guidance and Instructions on Electronic Filing of Broker-Dealer Annual Reports) (February 2017). 

3. Securities Exchange Act Release No. 91128 (February 12, 2021) (Order Extending the Annual Reports Filing Deadline for Certain Smaller Broker-Dealers).

4. Once a member that meets the conditions set forth in the SEC’s order submits the required notification to FINRA, the notification need not be submitted again for as long as the member continues to meet those conditions. If a member no longer meets the conditions of the SEC’s order, it may not continue to avail itself of the 30-day extension.

5. See FINRA News Release, SIPC and FINRA Streamline Reporting Process for Broker-Dealers (August 1, 2017).

6. A Fifth FOCUS Report is an additional report that is due from a member firm whose fiscal year end is a date other than a calendar quarter.

7. See Regulatory Notice 12-11 (Supplemental FOCUS Information) (February 2012).

8. See Regulatory Notice 16-11 (Supplemental FOCUS Information) (April 2016).

9. See Regulatory Notice 14-43 (SEC Approves Supplemental Inventory Schedule) (October 2014).

10. See Information Notice 6/3/21 (Redesigned eFOCUS System and SEC Security-Based Swap Reporting Requirements; Revised Supplemental Inventory Schedule).

11. See Regulatory Notice 21-31 (FINRA Establishes New Supplemental Liquidity Schedule) (September 2021).