Regulatory Alerts2026-02-06 | Regulatory Notice 26-03Added · Updated
Guidance on Negative Consent for Bulk Transfer or Assignment of Customer Accounts
FINRA eliminates the requirement for members to submit draft negative consent letters for staff review and 'no objection' prior to bulk account transfers, a change effective April 1, 2026. The notice consolidates prior guidance to permit negative consent in specific bulk transfer scenarios, such as firm closures, mergers, or business line divestitures, provided members obtain prior written customer authorization. Members must adhere to effective practices including providing at least 30 days' notice, disclosing opt-out procedures and fee waivers, and ensuring compliance with applicable laws like Regulation S-P and Exchange Act Rule 15c3-3.
Topics
Share