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Information Notice 11/14/25

| United States
AI Analysis

Executive Summary

FINRA Information Notice 11/14/25 summarizes SEC amendments to SEA Rule 17a-5 mandating electronic filing of broker-dealer annual reports, supplemental reports, and Form 17-H on EDGAR in PDF format, alongside FOCUS Report updates including electronic signatures and elimination of notarization. These changes modernize submissions, eliminate paper filings to the SEC, and impose new interactive data requirements with phased compliance, requiring broker-dealers to secure EDGAR access and adapt processes promptly to avoid disruptions.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] #

What Changed

- Electronic Filing Mandate: SEC no longer accepts paper submissions of annual reports (Form X-17A-5 Part III), supplemental reports under SEA Rule 17a-5(k), and Form 17-H; all must be filed on EDGAR in PDF format.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] - Electronic Signatures Permitted: Allowed for all SEA Rule 17a-5 reports (including annual and FOCUS Reports) via specified processes, e.g., Adobe Acrobat digitally signed certificates with document locking; FOCUS Report Parts II and IIA now require signature by one principal executive or financial officer.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] - Oath or Affirmation Updates: Notarization eliminated; signed version must be retained for at least 6 years (first 2 in easily

What You Need To Do

  • Implement electronic signature processes (e
  • Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization)
  • Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance)
  • Direct questions to firm's Risk Monitoring Analyst.[https

Key Dates

June 30, 2025 Electronic PDF filing on EDGAR mandatory for annual reports (fiscal years ending on/after this date), supplemental reports (SEA Rule 17a-5(k)), and Form 17-H; no paper accepted.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
December 31, 2025 Reference date for determining firm net capital threshold ($250,000+) for interactive data compliance phasing. DEADLINE
June 30, 2027 Interactive Data File requirement applies to filings due on/after for firms with ≥ $250,000 minimum net capital (as of 12/31/2025). DEADLINE
June 30, 2029 Interactive Data File requirement applies to filings due on/after for firms with < $250,000 minimum net capital (as of 12/31/2025). DEADLINE
As early as possible pre-due date Submit Form ID for EDGAR access (5-7 business day approval delay).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]

Compliance Impact

Urgency: High – Immediate action needed for EDGAR access and PDF filings (past June 30, 2025 deadline as of January 2026), risking filing rejections or enforcement if unprepared; interactive data adds future burden but allows planning. Matters due to SEC's zero-tolerance for paper, potential delays in EDGAR approvals, and operational shifts in signing/retention, amplifying risks for non-compliant

Who is Affected

All FINRA member broker-dealers required to file annual reports under SEA Rule 17a-5, including those submitting FOCUS Reports (Parts II/IIA).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]Firms without prior EDGAR access (need Form ID submission).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]Larger firms (minimum fixed-dollar net capital ≥ $250,000 as of 12/31/2025) face earlier interactive data deadlines; smaller firms (< $250,000) have later compliance.

References

Summary

Information Notice 11/14/25

Sectors

Capital Markets & Trading

Topics

Reporting & Disclosure

Relevant Firm Types

Broker Dealer
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