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Broker-Dealer 2012 Firm Assessments: Time to Pay

April 9, 2012
FINRA new electronic billing system, E-Bill, enables firms to view and pay invoices through the FINRA Firm Gateway - an online tool that provides centralized access to FINRA regulatory and filing applications. FINRA member firms can use E-Bill to pay its 2012 Assessments Invoice that each firm should have received late last week - in a letter dated 4/6/12.  The Invoice covers each firm's 2012 Gross Income Assessment (GIA) and Personnel Assessment (PA).  Please note that these fees may be paid in four equal installments. Gross Income Assessment (GIA) and Personnel Assessment (PA). As announced in Regulatory Notice 09-56, FINRA made changes effective 1/1/10, to its member regulatory fee structures, specifically a 3-year average of GIA Fees and the increase in Personnel Assessment Fees.  Below is a brief description explaining each of these assessments.  There are no changes to the 2012 Gross Income Assessments. Gross Income Assessment. Calculation of the 2012 GIA amount will remain the same.  The “GIA – Current Year Calculation” value on the invoice will be presented at gross - i.e., not net of the rebate amount).  In order to provide consistency, the GIA amounts from years 2010 and 2011 - which now are displayed on the invoice - are used for calculating the average, will also be presented at gross.  The Member Rebate will be subtracted at the end of the invoice
  • Number of Years. In certain cases, the number of years for the average could be <3 years. Some examples are firms that did not have GIA amounts in the previous years.  If the GIA fee was calculated as zero then it is still counted in the average.  For example, if a member only began paying GIA in 2011, then the 2011 and 2012 GIA amounts should be added and then divided by two.
  • Mergers and Acquisitions. In cases where 2 firms have been merged and are using a single Customer ID, the GIA amounts for the 2 customers is combined for all years used in the calculation of the average.
Personnel Assessment. Each firm pays an annual Personnel Assessment Fee based on the number of principals and representatives under a tiered rate structure.  The 2012 Personnel Assessment Fee has not changed.  The fee structure is listed below:

# Reps New Fee 1-5    Reps   ---   $150/rep 6-25 Reps   ---   $140/rep 26+  Reps   ---   $130/rep

The PA Fee invoice shows the tiers and number of billable principals and representatives.  The total number of principals and representatives is derived directly from the number of billable registered representatives registered with FINRA as of 12/31/11. Firms can view their GIA invoice online and submit payment via wire transfer or ACH (or online by credit card).  As in the past, you may also pay via check. Payment. All firms have the option to pay the entire invoice upon receipt, or in four installments.  Those on the installment method will not receive additional invoices.  Installments are paid, as follows:
  • 25% of total invoice due upon receipt;
  • 25% of total invoice by 6/1/12;
  • 25% by 9/1/12;  and,
  • final 25% by 12/1/12.
For further details, go to: [FINRA Letter with 2012 Invoice to Member Firms, 4/6/12].