FINRA New Member Application Support

Launching a broker-dealer is a complex endeavor. ACI provides comprehensive support for firms navigating the FINRA New Member Application (NMA) process – helping you demonstrate preparedness, meet regulatory expectations and start your business in full compliance.

Our FINRA New Member Application support services include:

Standard 2 Capitalization Structuring

A successful application starts with a compliant, defensible capital plan. ACI works with you to structure initial capitalization that aligns with your business model and satisfies FINRA’s financial responsibility rules.

Standard 7 Pro-Forma Financial Statements

Pro-forma financials offer regulators a window into your planned operations. ACI develops detailed, GAAP-compliant financial projections that reflect your business model and internal controls.

Stress Test Modeling

FINRA expects new firms to demonstrate resilience under adverse scenarios. ACI helps you build stress tests that illustrate financial durability and robust risk management.

Standard 8 Regulatory Reporting Responses

Responding to FINRA’s questions around regulatory reporting requires fluency in complex requirements. ACI ensures your firm’s controls and capabilities meet the mark.

Recommendations for Complementary Service Providers

Successfully launching a broker-dealer often requires a complete bench of trusted vendors. ACI can help you assemble a team of compliance, legal, technology and banking partners to support your operations.

For firms sharing office space or infrastructure with a third party, FINRA requires transparent, well-documented expense sharing arrangements. ACI assists with ESA language that satisfies Standard 9 and helps avoid pitfalls.

Questions on the FINRA New Member Application process or ACI’s support services? Here’s what you need to know.

What is the FINRA New Member Application (NMA), and who needs to file it?

The FINRA New Member Application (NMA) is a formal submission required for any firm seeking to register as a broker-dealer with FINRA. It’s a comprehensive evaluation of a firm’s business plan, financial controls, operational readiness and compliance infrastructure. All new broker-dealer applicants must file an NMA and receive FINRA approval before commencing operations.

Does FINRA require pro-forma financials to be GAAP-compliant?

Yes. FINRA expects financial statements and projections to follow Generally Accepted Accounting Principles (GAAP), including accrual-based accounting, footnotes and structured formats. ACI builds GAAP-compliant pro-forma financials that align with both regulatory expectations and your business model.

Do I need to stress test my financials as part of the NMA?

Yes. Under Standard 10, FINRA expects firms to demonstrate how they would maintain operations and capital adequacy under adverse conditions. ACI builds stress test models tailored to your risk profile and helps you document and explain the results in a way that satisfies FINRA examiners.

Does ACI support the entire application process or just financial modeling?

ACI provides end-to-end NMA FinOp support, including financial modeling, regulatory documentation, stress testing, ESA coordination and introductions to other service providers. Our team of licensed FinOps and CPAs ensures our portion of your submission reflects industry best practices and FINRA standards.

What are the most common reasons FINRA rejects or delays a New Member Application?

Common issues include inadequate capitalization, unrealistic or unsupported financial projections, vague business models, weak internal controls, missing or non-compliant Expense Sharing Agreements and incomplete documentation. ACI helps you avoid these pitfalls with detailed modeling, compliant documentation and full-cycle application support.

What is an Expense Sharing Agreement (ESA), and when is it required?

An ESA is a written agreement that outlines how costs are shared between your firm and any third party – including parent companies and affiliates – that pays expenses on your behalf. FINRA requires ESAs for any shared expenses, including rent, salaries, IT infrastructure, legal services and more.

How long does the NMA process take, and how can ACI help speed it up?

The typical NMA timeline is 6-8 months, depending on the complexity of your business and the quality of your submission. ACI helps expedite the process by preparing complete, defensible documentation upfront and proactively addressing common red flags before they become issues.