FINRA recognizes the current economic turbulence the spread of COVID-19 has caused small firms, in particular. With that in mind, FINRA is providing temporary relief for small firms with respect to 2020 Gross Income Statements and Personal Assessments (Annual Assessments).
Generally, payment of Annual Assessments is due in full within 30 days of receipt or in four quarterly installments. In 2020, FINRA is permitting small firms—identified under the FINRA By-Laws as having no more than 150 registered persons—to treat 2020 Annual Assessments as billed as of August 1, 2020, rather than as due upon receipt in April. Further, small firms that choose to do so will be allowed to pay 50 percent of the amount due on September 1, 2020, and the remaining 50 percent on December 1, 2020. If a small firm does not submit payment within 30 days of receipt, FINRA will assume the firm has chosen to make payment to FINRA via the two September 1 and December 1 installments. In addition, small firms that exit FINRA membership before September 1, 2020, will not be expected to pay the Annual Assessment for this year.
We at Integrated Solutions are advising our clients that although the bill need not be paid until August 2020, we think it is accruable currently for GAAP purposes unless a firm plans on withdrawing.
Please review the related FAQ on FINRA's COVID-19 page for more information, including guidance on how small firms should treat the deferred payments for net capital purposes.
Please reach out to your Integrated Solutions contact for further information on this or other topics.