Alert April 12, 2011

FINRA Delays Implementation Date for New Know-Your-Customer and Suitability Rules

On April 8, 2011, FINRA filed a notice of a proposed change that would delay the implementation date for FINRA Rule 2090 (Know Your Customer) and FINRA Rule 2111 (Suitability) from October 7, 2011 to July 9, 2012.  In its filing, FINRA noted that numerous member firms had requested a delay in the implementation date to allow additional time to determine the types of systems and procedural changes they need to make, to implement the changes and to educate associated persons and supervisors regarding compliance with the rules.  The proposed rule change delaying the implementation date was designated as a “non-controversial” rule change that is effective immediately upon filing.  FINRA provided guidance concerning the new Know-Your-Customer and Suitability rules in Regulatory Notice 11-02.