Information Notice 11/10/25
Executive Summary
FINRA Information Notice 11/10/25 provides due dates for 2026 and Q1 2027 filings of Annual Reports, FOCUS Reports, Form Custody, and various supplemental schedules under SEA Rule 17a-5 and FINRA Rule 4524. It matters because it ensures timely electronic submissions via FINRA Gateway, incorporates SEC amendments for EDGAR PDF filings (with future Interactive Data requirements), and highlights a 30-day extension option for qualifying smaller firms, helping prevent compliance failures amid federal holidays. https://www.finra.org/rules-guidance/notices/information-notice-20251110 #
What Changed
- Electronic Filing Mandates: All specified filings must be submitted electronically via FINRA Gateway; SEC no longer accepts paper Annual Reports, requiring EDGAR PDF submissions under amended SEA Rule 17a-5(d)(6)(i). https://www.finra.org/rules-guidance/notices/information-notice-20251110 - SEC Interactive Data Compliance Dates: Annual reports and supplements must be filed as Interactive Data Files per Rule 405 of Regulation S-T; firms with net capital ≥$250,000 (as of Dec 31, 2025) comply for filings due ≥June 30, 2027; others ≥June 30, 2029. https://www.finra.org/sites/default/files/2025-11/Information-Notice-20251110.pdf - 30-Day Extension for Annual Reports: Available under SEC February 2021 order for qualifying SIPC members (e.g., smaller firms facing audit burdens), requiring FIN
What You Need To Do
- Submit all filings electronically via FINRA Gateway by 11
- For 30-day extension
- Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable
- Prepare for Interactive Data
- Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site
- Larger firms
Key Dates
Compliance Impact
Urgency: High – Multiple imminent deadlines (e.g., January 27-29, 2026 for Q4 2025 filings, just days from today), mandatory electronic/EDGAR shifts, and late fees/exam risks for misses; smaller firms gain extension relief but must notify promptly. Non-compliance risks enforcement under SEA Rule 17a-5, operational disruptions, and audit delays. https://www.finra.org/rules-guidance/notices/informat
Who is Affected
Summary
Information Notice 11/10/25