FINRA will be assessing and collecting from certain member firms an accounting support fee (GASB Accounting Support Fee) to adequately fund the annual budget of the Governmental Accounting Standards Board (GASB).  For 2012, total fees amount to $8,451,300, which will be collected in installments of $2,112,825 per quarter. Which FINRA Member Firms Must Pay. Only those firms that report trades to MSRB will be assessed a fee, which will be based on its portion of the total par value of municipal securities transactions reported by FINRA member firms to the MSRB during the previous quarter.  The first invoices for 2012 will be sent out in April, and will be based on trading activity during the Q1 of 2012.  Firms whose quarterly fees are less than $25 (i.e., de minimis) will not have to pay a fee that quarter.  Such de minimis fees will be allocated to all other firms that must pay. Passing Along Fees to Customers. As noted in FINRA Regulatory Notice 11-28, because some firms may seek to pass the GASB Accounting Support Fee onto customers engaged in municipal securities transactions, FINRA will set out an estimated fee rate (per $1,000 par value), based on the GASB recoverable annual budgeted expenses reported to FINRA for that year and historical municipal security trade reporting volumes so that firms will have some basis on which to establish a fee should they choose to do so. Based on reported municipal trading activity by FINRA member firms in 2011 and the 2012 GASB budget, FINRA estimates that the GASB Accounting Support Fee for 2012 will be between $0.0027 and $0.0030 per $1,000 par value.  To the extent any member firms are excluded from the fee in a given quarter, those member firms with assessments of $25 or more will pay a slightly higher rate.

N.B. Keep in mind that, should your firm choose to pass along the fee, it must properly disclose the fee, including, if applicable, the fact that the fee is an estimate and that the firm ultimately may pay more or less than the fee charged to the customer.  In addition, any disclosure used by a member firm cannot be misleading and must conform to FINRA rules, including just and equitable principles of trade, as well as any applicable MSRB rules.

FINRA Staff Contacts. Direct questions to:  Finance Department, at (240) 386-5313;  Office of General Counsel, at (202) 728-8071. For further details:  [Regulatory Notice 12-15, March 2012].