FINRA has recently disciplined firms for failing to file a continuing membership application (CMA) because they expanded their operations or activities, or experienced a significant business event.  These violations were easily avoidable - unless the firms intended to purposely sidestep the requirements. Presuming they made honest mistakes, those firms may have lacked the common sense to notify FINRA, or seek its approval;  and, they forgot to look up NASD Rule 1017(a), Continuance in Membership Application or CMA, in the FINRA rulebook.  Lastly, they forgot to call upon an their outside legal or compliance adviser. FINRA Continuing Membership Guide. C-I introduces a fourth alternative, which would have been for them to visit the FINRA web site and click on the CM guide, which offers an introduction to the requirements, ways to expedite the process, and general ways to stay out of harm's way. Introduction. FINRA requires firms to file a continuing membership application (CMA) whenever they seek to expand their operations or activities, and for other business events, as indicated in NASD Rule 1017(a) (Continuance in Membership Application or CMA). Firms also must file an application whenever they seek to modify or remove restrictions previously imposed in a membership agreement (a membership agreement change or MAC). FINRA determines whether to approve, deny or approve with restrictions all such applications in accordance with the procedures in Rule 1017. In these applications, the overriding consideration is an applicant's ability to continue to meet the standards for membership contained in NASD Rule 1014 (Department Decision). Expediting the Process. NASD Rule 1017(g)(2) requires FINRA to issue a written decision for CMAs “within 30 days after the conclusion of the membership interview or the filing of additional information or documents, whichever is later. If the Department does not require the Applicant to participate in a membership interview or request additional information or documents, the Department shall serve a written decision within 45 days after the filing of the application under paragraph (a)….” However, the biggest factor that causes a delay in processing an application is whether sufficient information is supplied to support the request. In each case, FINRA is required to verify that the proposed expansion or change meets each of the 14 criteria for membership (see Rule 1014).  However, an effort is made to target the inquiry and limit the scope of analysis in each case consistent with FINRA’s obligations under the rules. Therefore, applicants must be prepared to provide in a timely manner information that addresses how they will satisfy all of the standards for admission and other applicable statutory and regulatory requirements if requested to do so. Firms are encouraged to contact their Coordinator or local District Office before filing a CMA if they have questions about documents and information that should be submitted, since applications containing all of the relevant information when they are first submitted tend to be processed more expeditiously. This Guide provides valuable insight into the information that FINRA is likely to consider when evaluating CMAs. These documents are not, however, intended to present a comprehensive list of all conceivable categories of information that may be relevant to an application, nor should they be interpreted to limit FINRA's discretion to request whatever information it determines is relevant to an application. In many cases, FINRA may need to request additional or different information depending on the specific facts and circumstances presented in particular applications in order to verify an applicant’s ability to continue to meet the 14 standards contained in Rule 1014. For further details, go to:   [FINRA Continuing Membership Guide].