FINRA is introducing a mandatory annual online certification process for the FINRA Entitlement Program.  The new requirements begin in November 2011 and impact only those organizations - firms and regulators - with more than one user. Certification Process. During the 4th quarter of each year - beginning this November, FINRA will designate a 30-day period during which Super Account Administrators (SAAs) must review their organizations’ user accounts and complete the certification.  They are certifying that users are entitled only to those applications and privileges necessary to perform their job responsibilities.

Note: SAAs are responsible for ensuring that users in their organizations who, in order to perform their job responsibilities, require access to applications in the FINRA Entitlement Program -and the sensitive data that those applications may contain - are properly entitled to those applications.  For security reasons, only one SAA may be designated per organization ID/CRD number. Firms with affiliates may designate the same SAA for each affiliate.

The certification serves 2 purposes:  (i) It helps FINRA to protect the integrity and confidentiality of regulatory, proprietary and personal information that it maintains;  (ii) it supports each organization’s compliance with the management of authorized user accounts on FINRA systems. What SAAs Should Expect. FINRA will contact SAAs in November 2011 to inform them that the 30-day certification period has begun, and to provide detailed instructions for completing the certification process.  SAAs must determine that:

• each user has a continuing need to access FINRA application(s) on the organization’s behalf;
• each user is entitled only to the applications and privileges needed to perform current job responsibilities; and
• only users who require access to sensitive data (e.g., Criminal History Record Information, Social Security or tax ID numbers, dates of birth) are entitled to access this type of data.

Failure to Certify on Time. When an organizations doesn't complete the online certification within the designated 30-day period, FINRA will disable the capability to create, edit and clone accounts for all administrators at the organization until the SAA completes the certification process. While the certification is once a year, organizations are encouraged to review their user accounts more frequently, taking into account company size, number of FINRA-entitled systems and staff turnover. For additional details, go to:   [FINRA InfoNote, 10/28/11]  and  [FINRA Entitlement Program – Super Account Administrator page]  and  [FINRA Entitlement User Accounts Certification Process FAQ]. Also refer to the FINRA Entitlement Program Agreement and Terms of Use for complete information. FINRA Contacts. Direct questions about the InfoNote to:   Mary Ann Shaw, Sr. Director, Information Ops [(240) 386-4806].   Direct questions about SAA or Entitlement Program to:  Gateway Call Center [(301) 869-6699].