FINRA New Member Application: How to Become a Broker-Dealer, the Timeline and What FINRA Asks

To become a US broker-dealer, a firm files Form BD with the SEC through FINRA's Central Registration Depository (CRD) and files a New Member Application (Form NMA) to join FINRA. The SEC acts on Form BD within 45 days of a complete filing, but FINRA's review sets the timetable: FINRA must decide a substantially complete application within 180 calendar days. Since 15 April 2026 every new application uses FINRA's enhanced Form NMA, and the FINRA fee starts at $7,500 for a firm with 1 to 10 registered persons.

This guide explains who needs to join FINRA, what the application contains, the 14 standards FINRA tests, the timetable stage by stage, the capital and people FINRA expects, and how to prepare for the membership interview. Our US broker-dealer registration page covers the licence in full, and the SEC investment adviser and broker-dealer overview compares the two US investment registrations.

Who must become a FINRA member

A broker is a person in the business of effecting securities transactions for others. A dealer buys and sells securities for its own account as a business. Both must register with the SEC unless an exemption applies, and a registered broker-dealer must also join a self-regulatory organisation before it does business. For firms dealing with the public in over-the-counter securities, that means FINRA.

The firms that typically apply include retail brokerages and investment apps, introducing brokers that pass orders to a clearing firm, placement agents and boutique investment banks paid on securities transactions, market makers, operators of alternative trading systems and firms dealing in tokenised securities. A non-US broker can deal with some US institutional investors without registering within the limits of SEC Rule 15a-6, but a firm that markets actively to US investors or serves US retail customers needs a US broker-dealer.

The registration stack: SEC, FINRA, states and SIPC

The firm can start business only once all of these are in place. In practice, firms file Form BD and Form NMA together and register their people in parallel.

What the application contains

FINRA Rule 1013 lists the contents of a new member application, and FINRA's own guidance names the documents most often missing. An application FINRA considers not substantially complete is returned: the applicant has five days to fix it, after which FINRA rejects it and refunds the fee less a $500 processing fee.

• Form NMA and Form BD with schedules.
• Fingerprints for each associated person who must be fingerprinted.
• A detailed business plan covering all material activities at launch and any planned expansion.
• A trial balance, balance sheet, supporting schedules and net capital computation dated within 30 days before filing.
• Monthly projections of income and expenses for the first 12 months, with the reasoning.
• An organisation chart, a full ownership chart and a supervisory chart.
• Office locations and the person in charge of each.
• The securities to be sold, the customer types and the methods used to win customers, including online channels.
• Any market making, underwriting or proprietary positions.
• Communications and operational systems, with capacity, security, redundancy and disaster recovery.
• Final or proposed contracts with banks, clearing firms and service bureaus.
• The nature and source of capital, with evidence such as the previous three months of bank statements, and every financing arrangement.
• Written supervisory procedures, compliance policies and corporate documents.
• Disclosure of any regulatory action, civil action, customer complaint or criminal matter involving the firm or its people.

The 14 standards FINRA tests

FINRA Rule 1014 sets 14 standards for admission. FINRA grants membership only if the applicant meets every one. Certain disciplinary events create a presumption that the application should be denied, which the applicant can rebut by showing it still meets each standard.

Form NMA is organised by these standards. Each section opens with the standard and then asks the questions that show how the applicant meets it, so a well-prepared application answers the standards directly.

FINRA Regulatory Notice 26-09 of 23 March 2026 introduced an enhanced Form NMA as part of its FINRA Forward programme. It launched on 15 April 2026, and the legacy form retired on 15 July 2026, with unsubmitted legacy drafts purged after 14 July. The rules FINRA applies to applications did not change.

The new form lets applicants upload a document once and reference it across sections, saves progress automatically, marks required fields, replaces many free-text boxes with structured fields and splits compound questions. It also asks applicants to state whether they will act as broker, dealer or both, and the number of markets they will make above and below $5 a share. FINRA's stated aim is fewer follow-up requests, which rewards an application that answers each field completely the first time.

The timeline, stage by stage

The 180 days run from FINRA's receipt of a substantially complete application. The applicant's speed of response is the main variable.

FINRA recommends responding well inside the 60 days rather than taking the full period. It also offers a Fast-Track review for suitable applications, judged on risk, complexity, completeness, scale and scope, where the applicant agrees in writing to shorter response times. An application can lapse if the applicant misses deadlines, lets scheduled exams expire, fails to attend the interview or does not return the signed membership agreement.

Net capital and the funding FINRA expects

SEC Rule 15c3-1 sets the minimum net capital, which is the firm's net worth after deducting illiquid assets and applying haircuts to securities positions.

• $5,000 for a broker that does not receive or hold customer funds or securities and carries no accounts.
• $50,000 for an introducing broker that receives but does not hold customer securities.
• $100,000 for a dealer.
• $250,000 for a firm that carries customer or broker-dealer accounts.
• For market makers, $2,500 for each security in which they make a market, or $1,000 for securities priced at $5 or less, up to $1 million, and never below the figures above.

A new firm must also keep its aggregate indebtedness within 800% of net capital for its first 12 months, before the normal 1,500% limit applies. FINRA's Standard 7 allows it to set a higher figure at launch, considering the capital needed to avoid early warning reporting, to meet expenses net of revenues for at least 12 months on agreed projections, and to support market making or underwriting. In practice, the 12-month projections in the application are what FINRA uses to test whether the firm is adequately funded, so the projections and the capital plan must agree.

People: principals, the FinOp and qualification exams

FINRA Rule 1210 requires at least two registered principals, normally General Securities Principals with the Series 24, unless the firm has only one associated person. A firm with a limited business can use principals registered in a limited category matching that business, and FINRA may waive the two-principal minimum where only one person should be required to register as a principal.

Every member needs a FinOp, the person responsible for net capital, books and records and financial reporting. Firms that self-clear or clear for others need separate principal financial and principal operations officers. The chief compliance officer named on Form BD registers as a Compliance Officer. FINRA's own guidance notes that the number of people who still need to pass exams affects how long an application takes.

The membership interview and the decision

Every applicant attends a membership interview with FINRA staff, with at least seven days' written notice naming who must attend. The interview tests whether the people who will run the firm can show how it meets the standards: how the business works, how trades are supervised, how net capital is computed and monitored, how customer money and securities flow, and how the firm handles anti-money laundering, communications and business continuity.

FINRA then grants membership, grants it with restrictions or denies it, and explains any restriction or denial by reference to the standards. Restrictions and denials can be appealed. A granted firm receives a membership agreement setting out the business it may conduct, signs it in FINRA Gateway within 25 days, and becomes a member. A later material change in business needs a continuing membership application under Rule 1017.

Crypto and tokenised securities in the application

The SEC's interpretation of 17 March 2026 states that most crypto assets are not themselves securities, while digital securities, including tokenised stocks and bonds, remain securities. A firm that will trade or hold crypto asset securities for customers needs a broker-dealer, and FINRA expects a prospective member to describe any crypto asset activity in its New Member Application. FINRA follows SEC guidance when assessing these business lines.

SEC staff stated on 17 December 2025 when a broker-dealer can treat itself as having physical possession of crypto asset securities under the customer protection rule, and on 17 September 2026 the SEC granted a temporary, conditional exemption for venues trading tokenised NMS stock. Applicants planning these activities should describe the custody model, the assets and the controls in detail, since the membership agreement will limit the firm to what it describes.

Preparing an application that moves on FINRA's timetable

• Settle the clearing model, capital and key people before filing. Large amendments during review can require a new application and fee.
• Put capital in the bank and evidence it.
• Write supervisory procedures for the actual business, not a template.
• Schedule exams so principals and the FinOp are qualified by the decision date.
• Keep Form BD and the application current throughout the review.

Firms that also give investment advice may need an adviser registration, explained in our guide to SEC or state registration for investment advisers. Once approved, the annual cycle of audits, FOCUS reports and certifications is set out in our guide to annual obligations for US advisers and broker-dealers. Our investment and wealth firms page covers our wider work for the sector.