One of the very important steps in FINRA’s new member application process (also referred to as the “NMA” process) is the FINRA membership interview. The FINRA membership interview is required by NASD Rule 1013(b)(1). A FINRA membership interview must occur with the prospective applicant prior to the issuance of a decision on any FINRA membership application. Rule 1013(b)(2) requires that FINRA provide the applicant with at least seven (7) days advance notice of a membership interview (in writing), unless the applicant and FINRA agree otherwise. The FINRA membership interview is 
required by Rule 1013(b)(3) to be scheduled no later than 90 days after the filing of the NMA application or 60 days after the last information request from FINRA has been satisfied, whichever comes later. Generally, the membership interviews are conducted at the FINRA district office in which the home office of the proposed broker-dealer is based.
What is the Purpose of the FINRA Membership Interview?
There are several purposes of the FINRA membership interview. Perhaps one of the most important is that it gives FINRA an opportunity for a face-to-face meeting with the applicant’s key players. FINRA may inquire of attendees about any topic related to the application or the operation of the proposed broker-dealer so it is important that the applicant be well prepared for the new member interview. It gives FINRA staff an opportunity to assess the readiness of these staff to run the broker-dealer. It also gives FINRA an opportunity to lay out its expectations for the principals of the firm. If there were any concerns with the information FINRA obtained as part of the application and it intends to base a membership decision on this information it is required, according to Rule 1013(b)(7), to provide this information to the applicant. Another important purpose of the interview is that it gives the prospective principals of the new broker-dealer an opportunity to discuss any issues, questions or concerns they have, or simply to ask any unresolved questions.
The membership interview is often conducted near the end of the application process. So it is important that any loose ends are tied up before this meeting.
Mitch Atkins, FINRA’s former South Region Director, has extensive experience with FINRA new member applications and is a FINRA NMA expert. If you have questions about a FINRA NMA, contact Mitch Atkins, Principal of FirstMark Regulatory Solutions at 561-948-6511.