US Broker-Dealer Registration: Form BD, the FINRA New Member Application, Net Capital and Timeline
How to register a US broker-dealer: Form BD, the FINRA New Member Application and 180-day review, net capital from $5,000, Series 24 and 27, annual audits.
Key dates for 2025 to 2027
| 3 December 2025Passed | Regulation S-P amendments apply to broker-dealers that are not small entities: incident response programme and 30-day customer notice. |
|---|---|
| 15 April 2026Passed | FINRA's enhanced Form NMA launches in FINRA Gateway and becomes mandatory for every new application. |
| 3 June 2026Passed | Regulation S-P amendments apply to smaller broker-dealers. |
| 17 September 2026Passed | The SEC grants a five-year conditional innovation exemption for venues trading tokenised NMS stock and their liquidity providers. |
| 7 December 2026Upcoming | FINRA renewal programme: full payment of the preliminary statement due to renew firm, branch and individual registrations for 2027. |
| 10 December 2026Upcoming | Broker-dealers file the annual statement identifying their independent public accountant under Rule 17a-5(f)(2), unless the engagement is continuing. |
| 31 December 2026Upcoming | Registered persons due to complete FINRA's Regulatory Element of continuing education for 2026 must do so. |
| 1 March 2027Upcoming | Audited annual reports on Form X-17A-5 Part III due on EDGAR for broker-dealers with a 31 December 2026 year end. |
Written and reviewed by the Regulatory Counsel team. Last reviewed: 20 October 2026.
The short answer
A firm that buys and sells securities for customers (a broker) or for its own account as a business (a dealer) registers with the SEC on Form BD and, before it starts, joins a self-regulatory organisation, which for most firms means FINRA. Form BD is filed through FINRA's Central Registration Depository (CRD), and the SEC must grant registration or begin proceedings within 45 days of a complete filing. The FINRA New Member Application (Form NMA) is the larger task.
FINRA must decide a substantially complete application within 180 calendar days. It has 30 days for its preliminary review, the applicant has 60 days to answer the first request and 30 days for later ones, every applicant attends a membership interview, and a granted applicant has 25 days to sign its membership agreement, which limits the firm to the business it described. Since 15 April 2026 applications use FINRA's enhanced Form NMA. The FINRA fee starts at $7,500 for 1 to 10 registered persons, plus $5,000 for firms that will clear and carry customer accounts.
Net capital runs from $5,000 for a firm that never handles customer money or securities to $250,000 for a firm that carries customer accounts, and FINRA can require more to cover 12 months of expenses net of revenue. A firm needs at least two registered principals, a financial and operations principal (Series 27 or 28) and a chief compliance officer. Once live, it files FOCUS reports, an annual audit by a PCAOB-registered accountant within 60 days of year end (1 March 2027 for a calendar-year firm) and annual FINRA certifications.
Key facts at a glance
| Regulators | SEC (registration), FINRA (membership, examination and rules), state securities regulators (state registration) and SIPC (customer protection membership) |
|---|---|
| SEC filing | Form BD through CRD. No SEC fee. Decision or proceedings within 45 days of a complete filing |
| FINRA filing | Form NMA through FINRA Gateway, with business plan, financial statements, 12-month projections, written supervisory procedures, ownership and supervisory charts and evidence of funding |
| FINRA decision period | 180 calendar days for a substantially complete application (FINRA Rule 1014). The FINRA Board may extend by up to 90 days for good cause |
| FINRA application fee | $7,500 (1 to 10 registered persons) to $55,000 (more than 5,000), plus $5,000 for clearing and carrying firms |
| Minimum net capital | $5,000, $50,000, $100,000 or $250,000 depending on the business (SEC Rule 15c3-1). Market makers hold $2,500 per security, or $1,000 for securities at $5 or less, up to $1 million |
| New firm leverage limit | Aggregate indebtedness of no more than 800% of net capital in the first 12 months, then 1,500% |
| Required principals | At least two General Securities Principals (Series 24), or principals in a limited category matching the business. One FinOp (Series 27 or 28) and a chief compliance officer |
| Representatives | SIE plus a representative exam such as the Series 7 ($395), with a Form U4 ($125 FINRA fee) and fingerprints for each person |
| Annual audit | Annual reports on Form X-17A-5 Part III, audited by a PCAOB-registered accountant, filed on EDGAR within 60 calendar days of year end |
| Customer protection | SIPC membership for most broker-dealers: up to $500,000 per customer, with a lower limit for cash |
| Crypto | Crypto asset securities and tokenised securities stay within broker-dealer rules. FINRA expects crypto plans in the NMA, or a continuing membership application for existing firms |
Speak to a licensing expert
Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What is the US Broker-Dealer Registration (FINRA)?
Broker-dealer registration is the licence a firm needs to effect securities transactions for others, or to buy and sell securities for its own account as a business, in the United States. It applies to retail brokerages and trading apps, introducing brokers, placement agents and investment banks paid on securities transactions, market makers and operators of alternative trading systems.
Three layers sit on top of each other. The firm registers with the SEC on Form BD. It joins FINRA, the self-regulatory organisation that writes and enforces most day-to-day rules for broker-dealers and examines them. It registers with each state where it does business, and most broker-dealers become members of SIPC, the Securities Investor Protection Corporation, which returns customer cash and securities up to set limits if a member fails.
The FINRA New Member Application is where most of the work lies. FINRA admits a firm only if it meets 14 standards covering its people, money, systems, supervision and contracts, and it grants membership for the business the firm described. Activity beyond that needs FINRA's approval later through a continuing membership application.
Who needs US Broker-Dealer Registration (FINRA)?
Any firm that is in the business of effecting securities transactions for others or dealing in securities for its own account with US customers, unless an exemption applies, such as Rule 15a-6 for non-US brokers with limited US contact.
- - Retail brokerages, investment apps and trading platforms executing securities trades
- - Introducing brokers that open customer accounts and pass orders to a clearing firm
- - Placement agents and corporate finance firms paid on securities transactions
- - Market makers and proprietary trading firms dealing with the public
- - Operators of alternative trading systems, which register as broker-dealers
- - Firms trading, holding or distributing tokenised securities or crypto asset securities
- - UK, EU and Asian brokers setting up a US broker-dealer subsidiary to serve US investors
The first misconception is that SEC registration is enough. A broker-dealer must also be a member of a self-regulatory organisation before doing business, and in practice FINRA's review, not the SEC's, sets the timetable. The second is that the cheapest net capital level can be chosen freely. The minimum follows what the firm does: receiving customer cheques, holding customer securities, carrying accounts or dealing all move the firm to a higher figure, and FINRA can set a higher figure still, based on 12 months of projected expenses net of revenue. The third concerns crypto. The SEC's March 2026 interpretation states that most crypto assets are not themselves securities, so trading only in those assets does not need broker-dealer registration. Tokenised stocks and bonds and other crypto asset securities remain securities, and firms dealing in them need a broker-dealer. Firms dealing only in non-security crypto assets usually need FinCEN registration and state money transmitter licences instead.
Form BD and the SEC's 45 days
Form BD is the uniform application for broker-dealer registration with the SEC, FINRA and the states. It is filed once through CRD and covers the firm's legal form, owners, direct and indirect control persons, types of business and any disciplinary history. The SEC charges no fee for Form BD.
Within 45 days of a complete filing the SEC must grant registration or begin proceedings to determine whether to deny it. The SEC may grant registration on condition that the firm obtains membership of a self-regulatory organisation, and the self-regulatory organisations run their own procedures, which are not bound by the 45 days. A non-US applicant also appoints the SEC as agent for service of process.
What the New Member Application contains
FINRA Rule 1013 lists the contents of a new member application. Form NMA is organised by FINRA's standards for admission, with each section stating the standard and then asking the questions that show how the applicant meets it.
- - Form NMA and Form BD with applicable schedules
- - Fingerprints for each associated person who must be fingerprinted
- - A detailed business plan covering all material activities at and after launch, including expansion plans
- - 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 behind them
- - Organisation chart, office locations and the person in charge of each office
- - Securities to be sold, customer types and methods used to win customers, including online channels
- - Market making, underwriting and proprietary positions, where planned
- - 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, all financing arrangements and any arrangement for additional capital
- - Written supervisory procedures and disclosure of any regulatory, civil, criminal or customer complaint history
The 14 standards for admission
FINRA Rule 1014 sets 14 standards. FINRA grants membership only if the applicant meets each of them, and certain disciplinary events create a presumption that the application should be denied, which the applicant can rebut.
| Standard | What FINRA checks |
|---|---|
| 1 | The application and all supporting documents are complete and accurate |
| 2 | The firm and its people hold every required federal, state and self-regulatory licence and registration |
| 3 | The firm and its people can comply with securities laws and FINRA rules, judged against disciplinary, complaint and regulatory history |
| 4 | Contracts with banks, clearing firms and service bureaus are in place to start the business and comply with the rules |
| 5 | Facilities are sufficient for the planned operations |
| 6 | Communications and operational systems are adequate and provide for business continuity |
| 7 | The firm can maintain net capital above the minimum on a continuing basis. FINRA may set a higher figure |
| 8 | Financial controls are in place |
| 9 | Compliance, supervisory, operational and internal control practices match industry standards for the business |
| 10 | A supervisory system with written supervisory procedures and enough qualified supervisors |
| 11 | Record keeping systems and staff to prepare and keep required records |
| 12 | A training needs assessment and written training plan |
| 13 | No information suggests the firm may evade securities laws or FINRA rules |
| 14 | The application is otherwise consistent with securities laws and FINRA rules |
The FINRA timeline, step by step
| Stage | Time limit |
|---|---|
| Applicant corrects an application that is not substantially complete | 5 days, or FINRA rejects it and refunds the fee less $500 |
| FINRA preliminary review and first information request | 30 days after a substantially complete application |
| Applicant responds to the first request | 60 calendar days |
| Applicant responds to later requests | 30 days each |
| Notice of membership interview | At least 7 days before the interview |
| FINRA written decision | 30 days after the interview or the last information filed, whichever is later |
| Overall limit | 180 days, extendable by the FINRA Board by up to 90 days for good cause |
| Applicant signs the membership agreement | 25 days |
FINRA also runs a Fast-Track review for suitable applications, where the applicant agrees in writing to shorter response times.
The enhanced Form NMA in 2026
FINRA Regulatory Notice 26-09 of 23 March 2026 announced an enhanced Form NMA. It launched in FINRA Gateway on 15 April 2026, and the legacy form retired on 15 July 2026, with unsubmitted legacy drafts purged after 14 July. Every application started on or after 15 April 2026 uses the enhanced form.
The enhanced form does not change the rules FINRA applies. It adds document cross-referencing, standardised answer fields, required-field markers and clearer questions, for example separate fields for the number of markets made in securities above and below $5 a share, which feed the net capital requirement. FINRA's aim is fewer follow-up requests, which rewards applicants that answer each field completely the first time.
Net capital: the minimum and what FINRA may require
Net capital is the firm's net worth after deducting illiquid assets and applying haircuts to securities positions. SEC Rule 15c3-1 sets the minimum by business type. A new firm must also keep aggregate indebtedness (most of its liabilities) within 800% of net capital for its first 12 months, rising to 1,500% afterwards, unless it elects the alternative standard of the greater of $250,000 or 2% of aggregate debit items.
FINRA's Standard 7 lets it set a higher figure for the start of operations, 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, underwriting or proprietary positions. Capital should be in the bank and evidenced when the application is filed.
| Business | Minimum net capital |
|---|---|
| Carries customer or broker-dealer accounts, or elects the alternative standard | $250,000 |
| Dealer | $100,000 |
| Broker exempt from the customer protection rule under (k)(2)(i) | $100,000 |
| Introducing broker that receives but does not hold customer securities | $50,000 |
| Broker that does not receive or hold customer funds or securities and carries no accounts | $5,000 |
| Market maker | $2,500 per security, or $1,000 per security at $5 or less, up to $1 million, and never below the figures above |
Principals and qualification exams
FINRA Rule 1210 requires each member, other than a member with only one associated person, to have at least two officers or partners registered as General Securities Principals, or in a limited principal category that matches a limited business. FINRA may waive the two-principal minimum where only one person should conclusively be required to register as a principal.
Each member also needs a financial and operations principal (FinOp), and firms that self-clear or clear for others designate a separate principal financial officer and principal operations officer. The chief compliance officer named on Schedule A of Form BD registers as a Compliance Officer, either by passing the Series 14 or by holding the Series 7 and Series 24. Representatives pass the SIE and a representative exam, and most states also require the Series 63.
| Exam | Role | Fee |
|---|---|---|
| SIE, Securities Industry Essentials | Entry exam taken with any representative exam | $100 |
| Series 7 | General Securities Representative | $395 |
| Series 24 | General Securities Principal | $235 |
| Series 27 | Financial and Operations Principal, required for carrying, clearing and alternative-standard firms | $235 |
| Series 28 | Introducing Broker-Dealer FinOp | $195 |
| Series 14 | Compliance Officer | $450 |
| Series 57 | Securities Trader Representative | $105 |
| Series 79 | Investment Banking Representative | $395 |
| Series 82 | Private Securities Offerings Representative | $100 |
| Series 63 | State law exam for broker-dealer agents (NASAA) | $147 |
State registration, SIPC and individual registration
Form BD also serves as the application to the states. Each state where the firm does business has its own registration requirements and fees, collected through CRD, and agents generally register in each state where they deal with customers.
Most broker-dealers become SIPC members and pay an annual assessment. SIPC returns customer cash and securities up to $500,000 per customer if a member is liquidated, with a lower limit for cash claims. Individuals are registered on Form U4, with a $125 FINRA fee for each initial Form U4 and a $20 FINRA processing fee for each electronic fingerprint submission.
Supervision and annual FINRA obligations
- - Rule 3110: written supervisory procedures, designated supervisors and an annual compliance meeting with each registered person
- - Rule 3120: principals test the supervisory control system and report to senior management at least once a year
- - Rule 3130: the chief executive certifies each year that the firm has processes to maintain, review, test and update its compliance policies and supervisory procedures
- - Rule 3310: an AML programme with annual independent testing on a calendar-year basis, or every two years for firms with no customer business
- - Rule 4370: a business continuity plan reviewed every year and updated after material changes
- - Rule 1240: each registered person completes the Regulatory Element of continuing education by 31 December each year in which it falls due
Annual audited reports and FOCUS filings
SEC Rule 17a-5 requires each broker-dealer to file annual reports: audited financial statements and supporting schedules, a compliance report or an exemption report depending on whether it is subject to the customer protection rule, and the accountant's reports on them. The auditor must be independent and registered with the PCAOB. The annual reports are filed on EDGAR, with FINRA and with SIPC, within 60 calendar days of the financial year end, which is 1 March 2027 for a firm with a 31 December 2026 year end.
Each firm also files a statement identifying its independent public accountant by 10 December each year, unless the engagement is continuing, or within 30 days of registration if earlier. Through the year, firms that neither clear nor carry customer accounts file FOCUS Part IIA within 17 business days after each quarter end, carrying and clearing firms file Part II quarterly and Part I monthly, and firms file Form Custody quarterly.
Crypto asset securities and tokenised securities
On 17 March 2026 the SEC, joined by the CFTC, issued an interpretation that most crypto assets are not themselves securities, while digital securities, including tokenised equity and debt, remain securities. A broker-dealer is needed to effect transactions in crypto asset securities for customers or to deal in them as a business.
SEC staff stated on 17 December 2025 when a broker-dealer may treat itself as having physical possession of crypto asset securities under the customer protection rule. On 17 September 2026 the SEC granted a temporary, conditional innovation exemption for tokenised securities venues trading tokenised NMS stock, including a conditional exemption from dealer status for liquidity providers, set to expire five years after publication.
FINRA expects a prospective member that plans crypto asset activity to describe it in its New Member Application under Rule 1013, and an existing member making a material crypto-related change to file a continuing membership application under Rule 1017. FINRA follows SEC guidance when assessing these business lines.
Introducing broker versus self-clearing broker-dealer
The clearing model drives capital, people and reporting more than any other choice.
| Point of difference | Introducing broker (fully disclosed) | Self-clearing or carrying firm |
|---|---|---|
| Customer funds and securities | Held by the clearing firm | Held by the firm under the customer protection rule |
| Minimum net capital | $5,000 if it receives no customer funds or securities, $50,000 if it receives but does not hold securities | $250,000 |
| FinOp exam | Series 28 or Series 27 | Series 27, plus separate principal financial officer and principal operations officer |
| FINRA application fee | Tier fee by headcount | Tier fee plus $5,000 |
| FOCUS reporting | Part IIA quarterly | Part I monthly and Part II quarterly |
| Annual report on customer protection | Exemption report | Compliance report |
FINRA New Member Application fees (By-Laws Schedule A, Section 4)
| Registered persons at filing | Application fee |
|---|---|
| 1 to 10 | $7,500 |
| 11 to 100 | $12,500 |
| 101 to 150 | $20,000 |
| 151 to 300 | $25,000 |
| 301 to 500 | $30,000 |
| 501 to 1,000 | $35,000 |
| 1,001 to 5,000 | $45,000 |
| More than 5,000 | $55,000 |
Add $5,000 if the applicant will clear and carry. A firm that withdraws within 30 days of filing, or whose application is rejected as incomplete, is refunded the fee less $500.
Key requirements
Form BD and Form NMA
Form BD reports the firm's identity, owners, control persons, business types and disciplinary history to the SEC, FINRA and the states. Form NMA, filed through FINRA Gateway, demonstrates how the firm meets each of FINRA's 14 standards for admission, with supporting documents.
Business plan and funding
FINRA Rule 1013 requires a detailed business plan covering all material activities and planned expansion, financial statements and a net capital computation dated within 30 days before filing, monthly income and expense projections for the first 12 months, and the nature and source of capital with supporting evidence, such as three months of bank statements.
Net capital
SEC Rule 15c3-1 sets the minimum net capital, which is liquid capital after deductions and haircuts. The figure depends on whether the firm receives or holds customer funds or securities, carries accounts, deals or makes markets. New firms keep aggregate indebtedness within 800% of net capital for their first 12 months.
Qualified principals and staff
A member needs at least two registered principals, a financial and operations principal, a chief compliance officer registered as a compliance officer, and qualified representatives. Each individual files a Form U4 and fingerprints, and passes the required exams before acting in that role.
Supervisory system and procedures
Written supervisory procedures assign each part of the business to a qualified supervisor. FINRA also expects compliance policies, an anti-money laundering programme with a designated officer, a business continuity plan, record keeping and a training plan under its continuing education rules.
Contracts and systems
Clearing, banking and service agreements must be in place or agreed in final form, and communications and trading systems must have adequate capacity, security, redundancy and disaster recovery. FINRA reviews copies of final or proposed contracts with banks and clearing firms.
What does broker-dealer registration cost?
Regulator fees are a small part of the cost of a broker-dealer. Net capital, qualified principals, clearing arrangements, systems and the annual audit are the main items.
- - SEC Form BD fee: none
- - FINRA New Member Application fee: $7,500 to $55,000 by number of registered persons, plus $5,000 for clearing and carrying firms
- - Individuals: $125 FINRA fee per initial Form U4, $20 FINRA processing fee per electronic fingerprint submission, and exam fees such as SIE $100, Series 7 $395, Series 24 $235, Series 27 $235 and Series 63 $147
- - State registration fees for the firm and its agents, collected through CRD, and annual FINRA renewal fees
- - Net capital: from $5,000 to $250,000 or more, held continuously, plus any higher figure FINRA sets
- - Third-party costs: PCAOB-registered auditor, clearing agreement, compliance and surveillance systems, SIPC assessment
- - Professional fees: a fixed fee set out in a written proposal
The application process
Define the business and the clearing model
We set the products, customers, revenue lines and clearing model, since these decide the net capital level, the principal categories, the FINOP exam and the FINRA fee. Most new firms introduce accounts to a clearing firm on a fully disclosed basis.
Reserve the name and set up access
The firm reserves its name and requests FINRA Gateway and CRD entitlement, then requests access to the enhanced Form NMA, which has been mandatory for new applications since 15 April 2026.
Prepare Form BD and the New Member Application
We prepare Form BD, Form NMA, the business plan, 12-month projections, net capital computation, written supervisory procedures, compliance and AML policies, business continuity plan, ownership and supervisory charts and contracts.
Register the people
Each associated person files a Form U4 and fingerprints. Principals and representatives schedule the SIE, Series 7, Series 24, Series 27 or 28 and any other exams so they are qualified by the time FINRA decides.
FINRA review and membership interview
FINRA confirms the application is substantially complete, completes its preliminary review within 30 days and issues information requests. We prepare every response within the 60-day and 30-day windows and brief the principals for the membership interview.
Decision, membership agreement and launch
FINRA grants, grants with restrictions or denies membership. A granted firm signs its membership agreement within 25 days, and it starts business once SEC, FINRA, SIPC and state registrations are effective.
FINRA must decide a substantially complete New Member Application within 180 calendar days, and the SEC acts on Form BD within 45 days of a complete filing. The FINRA timetable governs the launch date. Applications filed with capital in the bank, contracts agreed, procedures written and principals qualified move through on FINRA's published timetable; amendments after filing can delay the decision.
How long does broker-dealer registration take?
The SEC acts on Form BD within 45 days of a complete filing. FINRA must decide a substantially complete New Member Application within 180 calendar days, and the FINRA Board may extend that by up to 90 days for good cause. FINRA's own page notes that processing time depends on how many people must pass exams, the complexity of the business, how fully the applicant answers requests and whether SEC guidance is needed.
Inside the 180 days, FINRA completes its preliminary review within 30 days, the applicant has 60 days to answer the first request and 30 days for later ones, and the decision follows within 30 days of the interview or the last filing. After a grant, the firm has 25 days to sign the membership agreement.
The firm controls the start: capital in the bank, a clearing agreement agreed, supervisory procedures written for the actual business and principals already qualified.
Why applications fail, and how we prevent it
Application not substantially complete
Missing supervisory procedures, ownership or supervisory charts, corporate documents, funding evidence or a detailed business model lead FINRA to reject the application, refunding the fee less $500. We assemble the full package before filing.
A business plan that does not match the agreement needed
The membership agreement limits the firm to the business it described. Activities left out need a continuing membership application later. We draft the plan to cover the launch business and the planned next stage.
Capital that covers the minimum but not the plan
FINRA can require capital above the rule minimum to cover 12 months of expenses net of revenues, market making and other commitments. We build the capital plan from the projections FINRA will test.
Principals not qualified in time
Expired or unscheduled exams are grounds for an application to lapse. We plan each person's exam path alongside the application and track deadlines.
Changing the plan mid-review
Substantial amendments can delay the decision or require a fresh application and fee. We settle the business model, clearing firm and key people before filing.
Practitioner notes on broker-dealer applications
- - Choose the clearing model first. It sets net capital, the FinOp exam, the FINRA fee and the reporting cycle
- - Model 12 months of expenses net of revenue. FINRA can set capital at that level, above the rule minimum
- - Write the business plan for the business the firm will run in its first years, because the membership agreement limits it to what is described
- - Book exams early. A lapsed exam window is a ground for the application to lapse
- - Use the enhanced Form NMA fields fully. Complete first answers reduce follow-up requests
- - Classify every digital asset against the SEC's March 2026 interpretation before deciding between a broker-dealer and money transmission licensing
How we help
Model and structure
We set the business, the clearing model and the net capital level, and design the US entity, ownership and supervisory structure FINRA will review.
Form BD and New Member Application
We prepare Form BD, the enhanced Form NMA, business plan, projections, supervisory procedures and policies, and manage every FINRA request and the membership interview.
Post-approval compliance
We run FOCUS and annual audit timelines, net capital monitoring, the annual CEO certification, supervisory control testing and AML independent testing once the firm is live.
We obtain licences and run compliance for financial services firms in 65+ jurisdictions, US first, and broker-dealer registration is one of the most document-heavy applications we prepare. We build the New Member Application around the business the firm will actually run, so the membership agreement fits its plans. We answer every enquiry the same business day with a written proposal, and our professional fees are a fixed fee set out in that proposal.
Related licences
US SEC Investment Adviser and Broker-Dealer Registration
The overview of both US investment registrations, including routes for non-US firms.
US Investment Adviser Registration (SEC and State)
SEC or state registration, Form ADV, Series 65 and annual adviser filings.
FCA Investment Firm Authorisation
FCA permission, IFPR capital and SM&CR for UK investment firms.
Guides
Further reading on the US Broker-Dealer Registration (FINRA)
Frequently asked questions
File Form BD with the SEC through CRD, file the FINRA New Member Application through FINRA Gateway, register in each state where you will do business, join SIPC, and register each principal and representative on Form U4 with the required exams. You start business once all of these are effective.
FINRA must decide a substantially complete application within 180 calendar days. It completes a preliminary review within 30 days, you have 60 days to answer the first request and 30 days for later ones, and every applicant attends a membership interview.
$7,500 for 1 to 10 registered persons, rising by tier to $55,000 for more than 5,000, plus $5,000 if the firm will clear and carry customer accounts. The SEC charges no fee for Form BD.
$5,000 for a broker that never receives or holds customer funds or securities, $50,000 for an introducing broker that receives but does not hold customer securities, $100,000 for a dealer and $250,000 for a firm carrying customer accounts. FINRA can require more for the start of operations.
At least two principals with the Series 24 or a limited principal exam matching the business, a FinOp with the Series 27 or 28, a chief compliance officer with the Series 14 or the Series 7 and 24, and representatives with the SIE and Series 7 or another representative exam. Most states also require the Series 63.
FINRA launched an enhanced Form NMA on 15 April 2026 and retired the legacy form on 15 July 2026. The new form adds document cross-referencing, standardised fields and clearer questions, but the rules FINRA applies to applications are unchanged.
Within 60 calendar days of the financial year end, filed on EDGAR and with FINRA and SIPC. For a 31 December 2026 year end the deadline is 1 March 2027. The auditor must be an independent accountant registered with the PCAOB.
Only for crypto asset securities, such as tokenised stocks and bonds. The SEC's March 2026 interpretation states that most crypto assets are not themselves securities. Firms dealing only in non-security crypto assets usually need FinCEN registration and state money transmitter licences instead.
Yes, but a material change in business, including a material crypto-related change, needs FINRA approval through a continuing membership application under Rule 1017 before the firm starts the new activity.
Most registered broker-dealers are SIPC members and pay an annual assessment. SIPC returns customer cash and securities up to $500,000 per customer if a member is liquidated, with a lower limit for cash claims.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- SEC: guide to broker-dealer registration
- FINRA: register a new broker-dealer firm
- FINRA: after you apply
- FINRA Rule 1013: new member application and interview
- FINRA Rule 1014: department decision and standards for admission
- FINRA Rule 1017: continuing membership applications
- FINRA Regulatory Notice 26-09: enhanced New Member Application (23 March 2026)
- FINRA By-Laws Schedule A, Section 4: fees
- FINRA: SEA Rule 15c3-1 and related interpretations
- FINRA Rule 1210: registration requirements and minimum number of principals
- FINRA Rule 1220: registration categories
- FINRA: qualification exams and fees
- FINRA Rule 1240: continuing education
- FINRA Rule 3110: supervision
- FINRA Rule 3120: supervisory control system
- FINRA Rule 3130: annual certification of compliance and supervisory processes
- FINRA Rule 3310: anti-money laundering compliance programme
- FINRA Rule 4370: business continuity plans
- FINRA: annual audit filing
- FINRA: FOCUS reports
- FINRA: annual renewal programme
- SEC Release 34-100155: Regulation S-P amendments and compliance dates
- NASAA: general exam information for the Series 63, 65 and 66
- FINRA: crypto assets
- SEC press release 2026-30: interpretation on crypto assets (17 March 2026)
- SEC staff statement on custody of crypto asset securities by broker-dealers (17 December 2025)
- SEC press release 2026-90: innovation exemption for tokenised NMS stock (17 September 2026)
Last reviewed by the Regulatory Counsel team on 20 October 2026.