2025 Broker-Dealer Regulatory Filing Deadlines

Each year, FINRA members are tasked with submitting a range of filings, including audited financial reports, annual reviews, and other regulatory submissions. Tracking these obligations can be challenging due to the volume and varying requirements of each report. Understanding these deadlines is key to ensuring that filings are accurate and submitted on time.

Key Regulatory Compliance Filings for Broker-Dealers

In addition to the Annual Audited Financial Report, broker-dealers must manage several other filings, such as FOCUS reports and Form Custody. Each of these filings serves a distinct regulatory purpose and adheres to specific submission timelines throughout the year.

Annual Report

One of the most critical filings for broker-dealers is the Annual Audited Financial Report, due within 60 calendar days after the fiscal year-end. This filing is mandated under SEC Rule 17a-5(d), requiring broker-dealers to submit audited financial statements, including a statement of financial condition, statement of income, statement of cash flows and a statement of changes in stockholders’ or partners’ or sole proprietor’s equity.  An independent certified public accountant must conduct the audit, adding to the complexity of preparing the filing. Additionally, broker-dealers must submit the report electronically to FINRA and via overnight mail to the Securities and Exchange Commission (SEC). Meeting this deadline is essential, as late or incomplete filings can lead to fines or disciplinary action.

In February 2021, the SEC issued an order that permits specified firms an additional 30 calendar days to file their annual reports as required pursuant to SEA Rule 17a-5(d), subject to certain conditions.

FOCUS Reports

FINRA member firms, subject to minimum net capital requirements specific to the type of business they conduct, set forth in Rule 15c3-1, are required to compose and submit either quarterly or monthly Financial and Operational Combined Uniform Single (FOCUS) reports to FINRA pursuant to SEC Rule 17a-5. The FOCUS report must report a broker dealer’s net capital position as calculated under SEC Rule 15c3-1 (the SEC net capital rule) on a monthly or quarterly basis.

Form Custody

Registered firms are required to file Form Custody pursuant to SEA Rule 17a-5(a)(4). Form Custody was introduced to give regulators better insight into the practices broker-dealers use when handling customer funds and securities. Even though many broker-dealers may not actually hold or control these assets, they are still required to submit this form.

Supplemental Statement of Income (SSOI)

Firms must file the Supplemental Statement of Income (SSOI) on a quarterly basis.  The SSOI is a supplement to the Statement of Income (Loss) page of the FOCUS Report. The SSOI contains additional line items that seek a more detailed categorization of the revenues and expenses that are on the Statement of Income (Loss) page of the FOCUS Report Part II, Part IIA and Part II CSE. The SSOI is designed to help FINRA better understand a firm’s revenue sources and expense composition on an ongoing basis. 

Form OBS

Supplemental Schedule for Derivatives and Other Off-Balance Sheet Items requires all firms that carry customer accounts, or self-clear, or clear transactions for others (referred to, collectively, as “carrying or clearing firms”), to file with FINRA the OBS using the eFOCUS system within 22 business days of the end of each calendar quarter, unless the carrying or clearing firm meets the de minimis exception set forth in the instructions to the OBS. A firm that claims the de minimis exception must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period.

Supplementary Inventory Schedule (SIS)

The Supplemental Inventory Schedule (SIS) is designed to provide a more detailed categorization of a firm’s long and short inventory positions than what is required by the FOCUS Report Part II, FOCUS Report Part IIA and FOGS Report Part I. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA or FOGS Report Part I, and has inventory positions as of the end of the FOCUS or FOGS reporting period, unless the firm has (1) a minimum dollar net capital or liquid capital requirement of less than $100,000 or (2) inventory positions consisting only of money market mutual funds.

Supplemental Liquidity Schedule (SLS)

The Supplemental Liquidity Schedule (SLS), established in 2022 (see FINRA Notice 21-31) is designed to improve FINRA’s ability to look for events that signal an adverse change in the liquidity risk of the members with the largest customer and counterparty exposures. 

The SLS must be filed by each carrying member with $25 million or more in free credit balances, as defined under SEA Rule 15c3-3(a)(8), and by each member whose aggregate amount outstanding under repurchase agreements, securities loan contracts and bank loans is equal to or greater than $1 billion, as reported on the member’s most recently filed FOCUS Report, unless otherwise permitted by FINRA in writing. The SLS must be completed as of the last business day of each month and filed within 24 business days after the end of the month. A member need not file the SLS for any period where the member does not meet the $25 million or $1 billion thresholds.

Staying on top of regulatory filing requirements is essential for broker-dealers to maintain compliance. By understanding the purpose and deadline of each filing, whether it’s the Annual Audited Financial Report, FOCUS reports, or the SIPC Assessment, firms can better manage their obligations and demonstrate their commitment to regulatory excellence. A proactive and organized approach not only ensures accurate and timely submissions but also reinforces the firm’s reputation and operational stability in a highly regulated industry.

Regulatory Compliance Success with Oyster Consulting

Oyster Consulting has the expertise, experience and licensed professionals you need, all under one roof to protect your firm and your clients. Oyster’s regulatory compliance experts have the CCO, FINRA, SEC and state regulatory experience to help you solve complex regulatory challenges. Oyster Consulting provides outsourcing and compliance support to broker-dealers and investment advisors, including risk assessments, testing, remediation, outsourced compliance roles and automated compliance solutions.