FINRA provided clarification to member firms (e.g., broker-dealers, investment adviser firms, agents and investment adviser representatives, and branches) on reviewing, adjusting and responding to their "Final Statements" (i.e., fee adjustments) and renewal reports.

As previously covered, FINRA notified firms that:

  • their Final Statements and renewal reports became available on January 2, 2020; and

  • payment of the full amounts in the Final Statements are due by January 17, 2020.

FINRA clarified that:

  • if the Final Statement amount is greater than that of the preliminary statement, additional renewal fees must be paid by January 17, 2020;

  • any overpayments will be credited to the firm's Flex-Funding Account;

  • any discrepancies in a firm's Final Statement should be submitted to FINRA by January 17, 2020; and

  • firms are expected to "carefully" review their annual reports, and are recommended to keep them in their permanent records.