FINRA Continuing Membership Applications
Ownership & Control Changes
By Ed Wegener, Lisa Robinson, Jonathan Telfair and Armando Valdes
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Understanding the FINRA CMA Process
For broker-dealers, significant business changes often require filing a Continuing Membership Application (CMA) with FINRA (Rule 1017). These applications are complex, and missteps can result in costly delays. In this Oyster Stew episode, Ed Wegner, Practice Lead for Governance, Risk and Compliance at CRC-Oyster, is joined by former FINRA membership experts Lisa Robinson, Jonathan Telfair, and Armando Valdez to explore what firms need to know when facing ownership and control changes that trigger a CMA:
- When Does a CMA Apply?
- Preparing for the Filing
- New Challenges in the CMA Process
- The Role of Risk Monitoring Analysts
- Common Pitfalls
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Additional Resources
Dual Registration: Does It Make Sense To Separate?
Registering a Broker-Dealer: The NMA and CMA Process
From Application to Approval: Breaking Down Broker-Dealer Registration
Why Work with CRC-Oyster?
CRC-Oyster helps firms navigate the Continuing Membership Application (CMA) process with the advantage of deep, first-hand regulatory experience. Many of our consultants have held senior roles within FINRA’s Membership Application Program (MAP) and Risk Monitoring units, giving us unique insight into how applications are reviewed and where firms often encounter delays. We work closely with clients from the very beginning—helping them evaluate whether a filing is required under Rule 1017, preparing them for conversations with their FINRA Risk Monitoring Analyst, and organizing pre-file meetings to set the right tone. Our team guides firms in compiling complete transaction documentation, ownership charts, funding sources, and attestations, while also anticipating FINRA’s evolving focus areas, such as foreign ownership, AML due diligence, cybersecurity controls, and access to books and records. By preparing firms for the unexpected and ensuring their filings are thorough and strategically positioned, CRC-Oyster minimizes costly delays, helps avoid “rabbit holes” in the review process, and strengthens the likelihood of a timely approval—allowing broker-dealers to move forward with their business plans with confidence.
