FINRA Notice to Members 15-07 noted that the effective date of Rule 0190 is August 24, 2015. Rule 0190 is based largely on NASD IM-2420-1(a) (Transactions Between Members and Non-Members; Non-members of the Association). The rule confirms that a member firm will be considered as a non-member of FINRA from the effective date of any order or notice from FINRA or the SEC issuing a revocation, cancellation, expulsion or suspension of its membership.
Additionally, it should be noted that in the case of a suspension, a member firm will be automatically reinstated to membership in FINRA at the termination of the suspension period.
We hope that this information has been helpful to you. Should you have any additional questions or concerns, please feel free to contact Daniel E. LeGaye or Michael Schaps by e-mail or phone, at 281-367-2454, or consult with your legal counsel or compliance consultant. This legal update has been provided to you courtesy of The LeGaye Law Firm, P.C., 2002 Timberloch Drive, Suite 200, The Woodlands, Texas 77380.
The information contained herein is not, nor is it intended to be legal advice or establish or further an attorney-client relationship. All facts and matters reflected in this information should be independently verified and should not be taken as a substitute for individualized legal advice. You should consult an attorney for individual advice regarding your own situation. Not Board Certified by Texas Board of Legal Specialization. Michael Schaps is not an attorney.