2018 ARM Educational Conference. FINRA Registration & Disclosure Systems and Policy Updates March 6, 2018 Amelia Island, FL
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1 2018 ARM Educational Conference FINRA Registration & Disclosure Systems and Policy Updates March 6, 2018 Amelia Island, FL
2 Topics of Discussion Recent System Enhancements Industry Requests Form ADV E-Bill 2018 RAD Program Roadmap Form U4 SRO Registrations RAD Systems Transformation Individual Activities List Financial Professional Gateway FINRA Login Enhancements Disclosure & Sensitive Data Updates 2018 ARM Educational Conference Copyright 2018 FINRA 1
3 Recent System Enhancements
4 Initial Form BD (CIFER 292) New Broker-Dealer applicants are now able to submit the Initial Form BD electronically via Web CRD. Applicants are still required to mail a signed and notarized paper Form BD to FINRA after making their online submission. Updated guidance for new FINRA members is available online: ARM Educational Conference Copyright 2018 FINRA 3
5 Firm Disclosure Report (CIFER 296) A new Firm Disclosure Download report will display the following disclosure information for the firm: All DRPs from Form BD (including Part II, if completed). All DRPs from Form ADV (including Part II, if completed) 2018 ARM Educational Conference Copyright 2018 FINRA 4
6 Export Letters An export feature was added to the individual Outstanding Disclosure Letters queue, allowing users to obtain a CSV download of outstanding letters and details ARM Educational Conference Copyright 2018 FINRA 5
7 Search Functionality Changes In December 2016, search functionality was changed requiring users agree to additional terms and conditions when they search for former employees. This change also applied to Individual Snapshot report requests. Industry found the bifurcated search functionality to be counterintuitive and cumbersome ARM Educational Conference Copyright 2018 FINRA 6
8 Search Functionality Changes (cont.) In September 2017, a single search for current and former employees was re-introduced. When firms search for former employees, a pop-up message displaying the Terminated Individual Notice will display once per browser session ARM Educational Conference Copyright 2018 FINRA 7
9 Revised Form ADV Form ADV changes approved by the Securities and Exchange Commission (SEC) were implemented as of October 1, Highlights of SEC updates: Revisions across the form to fill data gaps and require advisers to provide additional information. Add Item 5.K questions and corresponding Schedule D tables to collect information about a firm s separately managed account business. Introduce Schedule R to allow private fund adviser entities operating a single advisory business to register using a single Form ADV. SEC Division of Investment Management: or IARDLIVE@sec.gov FAQs: ARM Educational Conference Copyright 2018 FINRA 8
10 Annual Amendment Completeness Checks Additional Completeness Checks will display when firms complete their first Annual Updating Amendment in the new form. IARD system will be available on Saturday, March 31, 2018, for advisers with a fiscal year end of December 31 to meet the 90 day filing deadline. (Screenshot is for illustration purposes only.) 2018 ARM Educational Conference Copyright 2018 FINRA 9
11 E-Bill AutoPay Firm users now have the option to set up AutoPay in E-bill for the following scenarios: Automatically pay outstanding invoices (e.g., TRACE, Advertising) Automatically replenish Flex-Funding Account if the balance falls below a specified amount 2018 ARM Educational Conference Copyright 2018 FINRA 10
12 2018 RAD Program Roadmap
13 2018 RAD Program Roadmap Q Q Q Q Financial Professional Gateway Release (January 25, 2018) Link to Prometric for exam appointments Web CRD, IARD & PFRD Release (February 24, 2018) Cboe rebrand Ongoing development in support of consolidated FINRA registration rules (deploys in Q4 2018) Minor bug fixes BrokerCheck Release (TBD) BrokerCheck usability enhancements (TBD) Web CRD Transformation (April 9, 2018) Pilot of firm-facing Individual Activities List Financial Professional Gateway Release (TBD) Ability for reps to view U5 filings notification to rep of U5 filing BrokerCheck Release (TBD) BrokerCheck usability enhancements (TBD) Web CRD Transformation (TBD) Add Firm and Branch Activities Lists Introduce Individual Profiles Entitlement Platform Migration (TBD) Replace login platform and implement security enhancements BrokerCheck Release (TBD) BrokerCheck usability enhancements (TBD) Web CRD, IARD & PFRD Release (October 1, 2018) Implement consolidated FINRA registration rules and qualifications exam restructure (including Securities Industry Essentials Exam) Web EFT Platform Migration (TBD) Begin process of migrating to a new Web EFT platform BrokerCheck Release (TBD) BrokerCheck usability enhancements (TBD) Registration Programs Public Disclosure Programs Transformation Initiatives 2018 ARM Educational Conference Copyright 2018 FINRA 12
14 Form U4 SRO Registrations
15 Form U4 SRO Registrations In connection with the October 1, 2018, qualifications exam restructuring, Section 4 of Form U4 will be reformatted to make selecting SRO registration categories more intuitive. Section 4 will be divided into the following four sub-categories: 1. Registered Representative Registrations 2. Principal Registrations 3. Retired Registrations 4. Registrations with no FINRA-administered underlying qualifying examination The changes described on the next two slides apply only to the online Form U4. Firms that upload filings via Web EFT will need to work with their internal technology departments or external service providers to achieve the same result through XML filings ARM Educational Conference Copyright 2018 FINRA 14
16 Form U4 SRO Registrations (cont.) Pre-populate all registered representative categories that an individual qualifies for with SROs a firm is a member of (if recognized by that SRO). To determine which categories to systematically select, CRD will evaluate the individual s Registration and Passed Exam History. Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 15
17 Form U4 SRO Registrations (cont.) For individuals with S24, prepopulate all principal level categories that correspond to the pre-requisites they are qualified for (if recognized by that SRO). Mockup General Securities Principal Research Principal Investment Banking Principal Securities Trader Principal Private Securities Offerings Principal 2018 ARM Educational Conference Copyright 2018 FINRA 16
18 Form U4 SRO Registrations (cont.) Retired registration categories and those without a FINRA exam will each have their own section on the Form. Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 17
19 RAD Systems Transformation
20 Individual Activities List The first pilot of new CRD functionality will include an Individual Activities List, as well as Quick Links and My Reports shortcuts ARM Educational Conference Copyright 2018 FINRA 19
21 Individual Activities List (cont.) The pilot will begin with a limited number of firms and then gradually expand. Pilot participants will receive additional entitlement in order to access the pilot functionality. As new functionality is added over the next few years, all users will be progressively transitioned to the new MyCRD entitlements as classic CRD functionality is phased out ARM Educational Conference Copyright 2018 FINRA 20
22 Financial Professional Gateway (FinPro) Today, FinPro has four features for currently registered representatives that can create efficiencies for firms: 1. Allow representative to review their CRD records and view reminders 2. Respond to firm requests to complete Form U4 3. Launch CE Online to complete Regulatory Element 4. Schedule or reschedule exam appointments 2018 ARM Educational Conference Copyright 2018 FINRA 21
23 Current Reps CRD Information Registered individuals can review their registration and disclosure information from CRD This can be useful for firms when completing annual certification activities 2018 ARM Educational Conference Copyright 2018 FINRA 22
24 Current Reps Reminders and U4 Edits receive reminders for current activities, including responding to firm requests to complete Form U4 filing Eliminates the need to copy/paste the filing reference number and send to the rep, along with a separate URL ARM Educational Conference Copyright 2018 FINRA 23
25 Current Reps CE Online launch the CE Online site Eliminates the need to provide reps with a separate URL for CE Online ARM Educational Conference Copyright 2018 FINRA 24
26 Current Reps Scheduling Exams and link to the Prometric site to schedule or reschedule exam appointments. Eliminates the need to provide representatives with a separate link for appointment scheduling ARM Educational Conference Copyright 2018 FINRA 25
27 Former Reps Residential Address Previously registered representatives are able to modify their current and previous residential addresses. Applies to formerly registered individuals still within 2 years of their last registration. This allows firms to direct former reps to FinPro as an alternative to submitting Form U5 amendments ARM Educational Conference Copyright 2018 FINRA 26
28 Future FinPro Vision Proposed future enhancements include: Allow representatives to view and print their Form U5. Generate notices for events such as: Regulatory CE element window is open Changes to CRD record via Form U4, Form U5 or Form U6 filing SRO and state registration changes (Pending Approved) 2018 ARM Educational Conference Copyright 2018 FINRA 27
29 FINRA Login Enhancements The current user verification product will be replaced by a more robust platform that will give FINRA greater flexibility to ensure system security. Web CRD and IARD are scheduled to be migrated to the new login platform this year. All FINRA applications will be migrated to the new login platform by the end of 2018 (exact dates for other applications are TBD). Other future enhancements being considered (deployment TBD): Multi-Factor Authentication A code sent to your phone or use of a token device as part of the login process ARM Educational Conference Copyright 2018 FINRA 28
30 Disclosure & Sensitive Data Updates
31 Sensitive Data Firms should exercise extreme caution when entering data in form filings, particularly free text and comment fields. Specific areas of concern include: Form U4 Section 13 Other Business Do not enter Social Security Number (SSN), Date of Birth, license numbers, etc. Financial and Customer Complaint DRP Comments Do not enter customer names, account numbers, third party contact information, etc. FINRA has provided additional guidance on protecting personal information: ARM Educational Conference Copyright 2018 FINRA 30
32 Disclosure Updates Public Records Review Disclosure Review RST Improvements Blank CHRI 2018 ARM Educational Conference Copyright 2018 FINRA 31
33 Public Records Review Improved Regulatory Review & Disclosure (RR&D) review: Double checked against a second Public Records vendor More complete information provided Source websites checked and links provided when possible Resulted in increased reportability 2015 = 33% disclosure rate 2017 = 65% disclosure rate Raised the bar for non-reportable explanations 2018 Financial PRR will be over the Summer 2018 Criminal PRR - letters should be sent by end of March 2018 ARM Educational Conference Copyright 2018 FINRA 32
34 Registration System Transformation for RR&D Items being considered include: Looking at all of RR&D processes Mass Transfer Disclosure Review Improved Org workflow (automate affiliate work) Utilize text analytics for more efficient triage Document Upload to FINRA Improved communication/notification to firms and potentially RRs through FinPro (link communication to specific occurrence) Firm tracker for status of disclosure review Improved submission cloning, improved Completeness Checks and warning messages 2018 ARM Educational Conference Copyright 2018 FINRA 33
35 National Fingerprint File (NFF)(blank CHRI) NFF States maintain and update CHRI locally and provide notification to the FBI rather than sending duplicate CHRI for the FBI to store and maintain NFF Participating States: Colorado, Florida, Georgia, Hawaii, Idaho, Iowa, Kansas, Maryland, Minnesota, Missouri, Montana, North Carolina, New Jersey, New York, Ohio, Oklahoma, Oregon, Tennessee, West Virginia and Wyoming* Over the last 3 years, approximately 1.25% of RAPP results were "Blank CHRI," which amounts to about 30 per month *list from FBI.Gov revised March 31, ARM Educational Conference Copyright 2018 FINRA 34
36 TEST SECURITY An Overview Questions 2018 Financial Industry Regulatory Authority (FINRA). All rights reserved. Materials may not be reprinted or republished without the express permission FINRA. Individuals, firms and data mentioned in these materials are fictitious and are presented exclusively for purposes of illustration or example ARM Educational Conference Copyright 2018 FINRA 35
37 2018 ARM Educational Conference FINRA Testing & Continuing Education Updates March 6, 2018 Amelia Island, FL
38 Agenda Exam Restructure Consolidation of Registration Rules Exploration of Potential Changes to the CE Program 2018 ARM Educational Conference Copyright 2018 FINRA 37
39 Mark the Date October 1, 2018 SEC approved SR-FINRA Consolidated FINRA registration rules Restructure of the Rep-level Qualification Exams Introduces Securities Industry Essentials Exam FINRA Regulatory Notice announced the rule changes FINRA will implement the new rules and make available the Essentials Exam on October 1, ARM Educational Conference Copyright 2018 FINRA 38
40 Qualification Exam Restructuring
41 Revised Rep-Level Exam Structure Series 99 Series 6 Series 7 Series 86/87 Essentials Exam Series 22 Series 82 Series 52 Series 79 Series ARM Educational Conference Copyright 2018 FINRA 40
42 SIE Answers to Essential Questions How many questions? 75 How long do I have? 105 minutes How long is it good for? 4 years Can I take it even if I do not work for a firm? Yes How much will the SIE cost? $60 (filing pending and SEC approval) 2018 ARM Educational Conference Copyright 2018 FINRA 41
43 SIE - Essential Facts Content Areas Covered: Knowledge of Capital Markets Understanding Products and Their Risks Understanding Trading, Customer Accounts and Prohibited Activities Overview of the Regulatory Framework 2018 ARM Educational Conference Copyright 2018 FINRA 42
44 Top offs Essential Facts Series 6 50 questions Series questions Series questions Series questions Series questions Series questions Series 86/87 100/50 questions Series questions 2018 ARM Educational Conference Copyright 2018 FINRA 43
45 Other Features of the Restructuring On October 1, 2018, FINRA will no longer offer the following exams: Series 11 Series 17/37/38 Series 42 Series 62 Series 72 Persons holding registrations associated with these exams will be able to continue to hold them until they leave the industry for more than 2 years ARM Educational Conference Copyright 2018 FINRA 44
46 Effect on Current Registrants Most current registrants will be considered to have passed the Essentials Exam, and it will be valid for 4 years upon leaving the industry. CRD will reflect this. Registrants who return between 2 and 4 years later will not need to take the Essentials Exam, only the top-off exam for the registration position. Registrants who return more than 4 years later will need to take both the Essentials and the top-off exam ARM Educational Conference Copyright 2018 FINRA 45
47 Preparing for October 1 Individuals who apply for registration on or before September 30 will take their exam under the current program, even if exam appointment date is on or after October 1. Individuals who apply for registration on or after October 1 will take the SIE and the revised qualification exam (i.e., SIE + Series 7) Individuals who take and fail an exam in September their next attempt will be the SIE and the revised qualification exam on or after October ARM Educational Conference Copyright 2018 FINRA 46
48 Essentials Exam Enrollment Options for Firms Through CRD, there will be two options for a firm to pay for an individual to take the Essentials Exam: Form U4 - request a representative level registration (e.g., GS) Non-Form U4: Enrollment system Individual one at a time Group upload a list of candidates Purchase vouchers which can be used by candidates to enroll for the exam 2018 ARM Educational Conference Copyright 2018 FINRA 47
49 SIE Enrollment & Results Non Registered Persons Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 48
50 Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 49
51 Reserved for mockup screens Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 50
52 Essentials Exam Enrollment for Individuals Will access enrollment system from finra.org Will need to create an account to pay exam fee Direct link to Prometric appointment scheduling Candidate will receive score report at test center Candidate can also view result in enrollment system 2018 ARM Educational Conference Copyright 2018 FINRA 51
53 Reserved for mockup screens Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 52
54 Change in Display of Exam Results in CRD Starting on October 1, 2018, CRD will show the following: For passing test results indicates the individual passed the exam For failing test results indicates the individual failed the exam and test score is displayed. Once an individual passes the exam, the failing results are no longer displayed. Only the passing result is displayed ARM Educational Conference Copyright 2018 FINRA 53
55 Change in Display of Exam Results in CRD (cont.) Why is this change being made? CRD is a system for maintaining registration information FINRA qualification exams determine whether a person has demonstrated minimum proficiency to act in a registered capacity Exam score is not intended to predict with how well a person will perform in a position (i.e., a person who scores 90 will not necessarily perform better than a person with a score of 75) Test scores will not be stored in CRD 2018 ARM Educational Conference Copyright 2018 FINRA 54
56 View Exam Results Registered Persons Exam section Mockup 2018 ARM Educational Conference Copyright 2018 FINRA 55
57 Viewing SIE Results Firms that pay the Essentials Exam fee will be able to view the individual s result If an individual pays the Essentials Exam fee, the firm will ONLY be able to view the result when: Conducting a pre-registration search Filing a Form U4 requesting a registration 2018 ARM Educational Conference Copyright 2018 FINRA 56
58 Web EFT Firm Impacts U4/U5 filing schemas & IIR/Posting report schemas will require several updates. Examples: Exam section will be updated for SIE & revised exams SRO Registrations section will be updated to add new registrations and remove retired registrations Details will be provided at the April 25, 2018, Web EFT conference call Draft schemas available June 2018 Web EFT testing begins August ARM Educational Conference Copyright 2018 FINRA 57
59 SIE Candidates Biometric Process at Testing Center When scheduling an appointment, candidate will be presented a biometric consent form At testing center check in: Fingerprint capture Scan of Candidate s ID Data will be used to: Control candidate s movement in and out of testing area during exam Compare against other fingerprints to detect proxy test takers 2018 ARM Educational Conference Copyright 2018 FINRA 58
60 Limited English Proficiency (LEP) Candidates with LEP can request 30 to 60 minutes extra time to complete a qualification examination FINRA conducted an analysis of LEP time usage Fewer than 3% of candidates request LEP extra time Most candidates use less than half of the extra time 2018 ARM Educational Conference Copyright 2018 FINRA 59
61 FINRA is Phasing out LEP Program FINRA will remove the LEP request functionality from CRD during the second quarter of 2018 Individuals for whom LEP has been approved will receive extra time on their exam 2018 ARM Educational Conference Copyright 2018 FINRA 60
62 FINRA Registration Rule Consolidation
63 Registration Rule Consolidation Implementation of registration rule consolidation on October 1, 2018, consists of three parts: Consolidated registration rules Permissive registration Financial services affiliate waiver program 2018 ARM Educational Conference Copyright 2018 FINRA 62
64 Consolidated Registration Rules Consolidates NASD and incorporated NYSE registration rules into FINRA registration rules (FINRA Rule 1200 Series) Requires firms to designate a Chief Financial Officer and a Chief Operations Officer (can be same person at non-clearing firms) 2018 ARM Educational Conference Copyright 2018 FINRA 63
65 Chief Compliance Officer Chief Compliance Officers will have a FINRA Compliance Officer registration requirement (Series 14 exam) Persons with a GS/GP (S7 and S24) can register as a Compliance Officer without taking the Series 14 exam 2018 ARM Educational Conference Copyright 2018 FINRA 64
66 New Principal Positions Investment Banking Principal S79 + S24 Private Securities Offering Principal S82 + S24 General Securities Principal (GP) will be limited to S7 + S ARM Educational Conference Copyright 2018 FINRA 65
67 Permissive Registration Allows permissive registration of persons engaged in a bona fide business purpose of a member Expands current NASD rule allowing for permissive registration of persons performing certain limited functions (e.g., legal, compliance, internal audit) Such persons would be subject to a level of supervision commensurate with their status 2018 ARM Educational Conference Copyright 2018 FINRA 66
68 Financial Services Affiliate Waiver Program (FSAWP) FSAWP will allow an individual working for a financial services affiliate of a member to receive a waiver of a qualification exam requirement upon returning to the member for up to seven years, provided the firm and the individual satisfy certain criteria 2018 ARM Educational Conference Copyright 2018 FINRA 67
69 Overview of FSAWP Process Firm files Form U5 for individual and s FINRA requesting FSA eligibility (must meet 10/5/1 rule) Member includes address for individual FINRA notifies individual via his/her FSA eligibility and individual s responsibilities to maintain eligibility, including CE requirement FINRA notifies individual via of each upcoming CE requirement with a link to enrollment page 2018 ARM Educational Conference Copyright 2018 FINRA 68
70 Overview of FSAWP Process (cont) When individual returns, firm files Form U4 and an FSAWP exam waiver request FINRA processes waiver request within 30 days Individual who has successfully maintained eligibility is granted an unconditional exam waiver 2018 ARM Educational Conference Copyright 2018 FINRA 69
71 Resources SR-FINRA Regulatory Notice Essentials web page: finra.org/industry/essentials-exam Exam Restructuring web page: finra.org/industry/exam-restructuring 2018 ARM Educational Conference Copyright 2018 FINRA 70
72 Exploration of Potential Changes to the Securities Industry Continuing Education Program
73 Current Program Structure Established in 1995 with two components: Regulatory Element Firm Element Intended to provide uniform training on regulatory matters Administered via an online platform as of 2015 Required on second anniversary of first registration and every three years thereafter Intended to address firmspecific topics Annual needs analysis and training plan High-level content requirements Learning materials developed by firms, FINRA, training providers 2018 ARM Educational Conference Copyright 2018 FINRA 72
74 Objectives of Program Review We are working with other securities regulators and the Securities Industry/Regulatory Council on Continuing Education to identify opportunities to: Increase timeliness of regulatory content Improve synergy between regulatory and firmprovided content Enable previously registered individuals to return to the industry through an alternative demonstration of qualification 2018 ARM Educational Conference Copyright 2018 FINRA 73
75 Program Vision A cohesive CE program and supporting platform that allows securities industry professionals to maintain their knowledge and qualifications throughout their careers 2018 ARM Educational Conference Copyright 2018 FINRA 74
76 A Cohesive Credit-Based CE Program We are considering an annual, credit-based requirement that harmonizes Regulatory and Firm Element programs Compulsory content will address timely regulatory changes and issues Elective content will address job and product-specific topics 2018 ARM Educational Conference Copyright 2018 FINRA 75
77 CE Content Compulsory Content Prioritized to keep CE demands reasonable May include just-in-time content based on triggering events May vary by registration category for some rules and issues Elective Content Clearer guidance for firm-developed content Broader access to offerings from FINRA and other providers 2018 ARM Educational Conference Copyright 2018 FINRA 76
78 A Supporting Platform Continuing education content will be launched from within the Financial Professional Gateway to ensure CE leverages the same platform that individuals will use for other gateway services. We will engage firms to identify and implement necessary platform features including tracking, notification and reporting capabilities. The platform will support both compulsory content and an elective content catalog ARM Educational Conference Copyright 2018 FINRA 77
79 A Mechanism to Maintain Qualification Status We are considering a mechanism by which individuals could maintain their qualification status when no longer associated with a member firm. Individuals who complete comparable CE and then re-associate with a member firm would satisfy the qualification requirements to regain their registrations. Requalifying by exam or qualifying for a waiver would not be necessary. This would replace the Financial Services Affiliate Waiver Program (FSAWP) ARM Educational Conference Copyright 2018 FINRA 78
80 Next Steps Further discussions with CE Council Further discussions with our peer regulators Focus groups with industry representatives Concept Release Regulatory Notice 2018 ARM Educational Conference Copyright 2018 FINRA 79
81 TEST SECURITY An Overview Questions 2018 Financial Industry Regulatory Authority (FINRA). All rights reserved. Materials may not be reprinted or republished without the express permission FINRA. Individuals, firms and data mentioned in these materials are fictitious and are presented exclusively for purposes of illustration or example ARM Educational Conference Copyright 2018 FINRA 80
82 2018 ARM Educational Conference FINRA CRD Transformation Effort March 6, 2018 Amelia Island, FL CRD transformation effort
83 CRD Transformation Benefits Tailored & Personalized Flexible Data Entry Less Administrative Burden Streamlined Regulatory View FinPro: One Stop for Reps Self-Service Reporting Communicate & Collaborate Better Systems Integration More Uptime for All Devices 2018 ARM Educational Conference Copyright 2018 FINRA 82
84 Tailored & Personalized User-defined dashboards Centralized inbox Quick links to frequently-used features Notification and alerts 2018 ARM Educational Conference Copyright 2018 FINRA 83
85 Flexible Data Entry Step-by-step guidance for filing activities Expert mode Machine-to-machine Access Instant editing 2018 ARM Educational Conference Copyright 2018 FINRA 84
86 Less Administrative Burden Electronic signature Branch management tool Flexible & quick search Single account for multiple firms In-system disputes & refund requests 2018 ARM Educational Conference Copyright 2018 FINRA 85
87 Streamlined Regulatory View Automated research & data analytics Configurable workflows Firm visibility into status of a review Seamless integration Dashboards tailored for managers 2018 ARM Educational Conference Copyright 2018 FINRA 86
88 FinPro: One Stop for Reps Access to their information Collaborate with their firm on updates Sign filings notifications and alerts 2018 ARM Educational Conference Copyright 2018 FINRA 87
89 FinPro: One Stop for Reps Periodic attestation Submit BrokerCheck comments Manage documents Pay FINRA fees 2018 ARM Educational Conference Copyright 2018 FINRA 88
90 Self-Service Reporting Query capability Templated reports Share and export Schedule reports delivery Request and track FINRA ad hoc reports 2018 ARM Educational Conference Copyright 2018 FINRA 89
91 Communicate & Collaborate Correspondence and document exchange Secure access control Correspondence audit trail Repository sharing between industry and regulators 2018 ARM Educational Conference Copyright 2018 FINRA 90
92 Better Systems Integration Electronic data access for registrations and amendments through direct systems interfaces (API) Near real-time data Improved security with multiple logins per firm 2018 ARM Educational Conference Copyright 2018 FINRA 91
93 More Uptime For All Devices 24x7 availability Support for phones and tablets ADA Section 508 compliance 2018 ARM Educational Conference Copyright 2018 FINRA 92
94 Think Big. Start Small. Delivery Incrementally Join The Pilot Program! ARM Educational Conference Copyright 2018 FINRA 93
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