FINRA pushed back the implementation date for new FINRA Rules 2090 and 2111 - "Know Your Customer" and "Suitability."  

The rules now will be implemented on 7/9/2012.  The original date was 10/7/11 - as announced in Regulatory Notice 11-02. 

In Regulatory Notice 11-25, issued 5/18, FINRA also provided Q&A's in response to recent industry questions and concerns, and directed members to contact James Wrona, Office of General Counsel [(202) 728-8270] with any questions.

    Background Info.   New FINRA "KYC" Rule 2090 requires firms to “use reasonable diligence, in regard to the opening and maintenance of every account, to know (and retain) the essential facts concerning every customer….” The rule explains that essential  facts are “those required to (a) effectively service the customer’s account, (b) act in accordance with any special handling instructions for the account, (c) understand the authority of each person acting on behalf of the customer, and (d) comply with applicable laws, regulations, and rules.”

New FINRA Suitability Rule 2111 requires that a firm or associated person “have a reasonable basis to believe that a recommended transaction or investment strategy involving a security or securities is suitable for the customer, based on the information obtained through the reasonable diligence of the member or associated person to ascertain the customer’s investment profile.”  In general, the new rules retain the core features of previous NASD and NYSE rules covering the same subject areas and codify well-settled interpretations of those rules. 

    New or Modified Obligations.   The rules create several new or modified obligations, and for this reason, a number of firms asked that the implementation date be pushed back - so as to allow more time to prepare new or update current procedures, modify automated systems, and educate their associated persons regarding compliance with the new or modified requirements. [C-I Note:  Of course, come July 2012, FINRA will expect all firms to be in FULL COMPLIANCE with the rules.  Meaning that examiners may take no prisoners for violations they find.]

    Q&A Session.   That said, it's time for some guidance.  Click the above link for RegNote 11-25 for the 11 Q&A's.