FINRA Rule 4530 became effective on July 1, 2011.  To help member firms implement FINRA Rule 4530, FINRA has published Regulatory Notice 11-32, which provides Questions & Answers relating to the rule's application. This guidance speaks solely to member firms’ reporting obligations pursuant to FINRA Rule 4530, and not to other applicable reporting requirements, including under Forms BD, U4 and U5.  FINRA, however, notes that a member firm is not required to report an event otherwise required to be reported under FINRA Rules 4530(a) or (b) if the member firm discloses the event on the Form U5, consistent with the requirements of that form. The requirements of FINRA Rule 4530 ... are based on similar requirements in NASD Rule 3070 and Incorporated NYSE Rule 351.  Rule 4530 strengthens, clarifies and extends these existing requirements by, among other things, requiring member firms to report certain internal conclusions of violations and financial-related insurance civil litigations and arbitrations, and clarifies the obligations of member firms with respect to written customer complaints and former associated persons.  Rule 4530 requires member firms to:

• report to FINRA certain specified events and quarterly statistical and summary information re: written customer complaints; and
• file with FINRA copies of certain criminal actions, civil complaints and arbitration claims.

FINRA previously issued RegNote 11-06 (February) to inform member firms of SEC approval of new FINRA Rule 4530, and RegNote 11-10 (March) to remind firms of their obligation to electronically report specified events and quarterly customer complaint information and to provide further guidance on automated reporting under the new rule. RegNote 11-32 now provides additional guidance. FINRA Staff Contacts.   Direct questions to:  Afshin Atabaki, Office of General Counsel - (202) 728-8902. Questions and Answers. FINRA addresses firms' reporting obligations for the following 4 major areas:

• Internal Conclusions of Violations.

• Customer Complaints.

• Financial-Related Insurance Civil Litigation.

• Former Associated Persons.

C-I Note: For now, we're asking members to read for themselves, by going to:   [FINRA RegNote 11-32, July 2011]  and [FINRA Rule 4530, Reporting Requirements] We'll publish take-aways as we analyze the Q&A's ourselves.  Stay tuned.