FINRA’s Residential Supervisory Location Reporting Requirements

In a continuation of FINRA’s implementation of the new Residential Supervisory Locations (RSLs) designation, they updated their Frequently Asked Questions (FAQs) on September 14, 2024 with streamlined reporting requirements for RSLs through the Form U4.

Firms are no longer required to submit a quarterly list of RSLs. Instead, firms must respond to a new question on Form U4 that asks firms to confirm whether an associated person's office of employment address, which is marked as a non-branch and a private residence, is designated as an RSL.

• Mandatory reporting: Firms that designated a location as a RSL between June 1, 2024 and November 25, 2024, must respond to the RSL question on Form U4 by December 26, 2024. Firms that designated an RSL on or after November 26, 2024, must respond to the RSL question within 30 days of designating an RSL.
• Transition period: Firms may voluntarily start responding to the new RSL question after September 14, 2024, but must fully comply by the November 26, 2024, implementation date.

It is important to note that the RSL question on the Form U4 requires firms to respond “Yes” or “No” when a location is marked as a private residential non-branch location. If "Yes" is selected, the firm confirms that the location has been designated as an RSL per Rule 3110.19. If “No” is selected, the firm confirms that, although the location is marked as a private residential non-branch location, it has not been designated as an RSL.

This specific Form U4 amendment is required for all private residential non-branch locations that are added to the Form U4, and not only ones that are designated as RSLs.

Our guidance

These updates simplify the RSL reporting process, allowing firms to provide FINRA with up-to-date information on RSL designations directly through the Form U4. Firms are encouraged to review and update their procedures to ensure compliance with FINRA’s definition of an RSL as well as the new reporting obligations.

How we help

Broker-dealers have a number of obligations for FINRA, the SEC, and other regulators. ACA Signature can help.

ACA Signature is a scalable solution curated to suit your firm’s unique compliance needs. We combine compliance advisory, innovative technology, managed services, and cybersecurity to effectively address regulatory commitments and day-to-day responsibilities, including assistance with U4 filings.

Reach out to your ACA consultant, or contact us to find out how we can help you launch, grow, and protect your firm.

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