FINRA highlighted changes to the Financial and Operational Combined Uniform Single ("FOCUS") reporting requirements following the SEC's September 2019 adoption of recordkeeping and reporting requirements for security-based swap (or "SBS") dealers.

FINRA stated that the new FOCUS reporting requirements and the modified SIS will apply to filings that must be filed in November 2021 with respect to a firm's financial condition in October 2021. Additionally, FINRA stated that quarterly filers can access the newly redesigned eFOCUS filing system starting on June 24, 2021, and monthly filers starting in July 2021.

Under the amendments:

  • FINRA members that presently file the FOCUS Report Part II will be required to file the modified FOCUS Report Part II;
  • FINRA members that presently file the FOCUS Report Part II CSE must instead file the amended FOCUS Report Part II, as FOCUS Report Part II CSE will be discontinued;
  • to avoid duplicative reporting requirements, FINRA members that file the amended FOCUS Report Part II will not be required to file the Supplemental Inventory Schedule ("SIS");
  • firms must use the amended Facing Page and Oath or Affirmation; and
  • there are no changes to FOCUS Report Part IIA.

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