Are firms required to submit a CMA for changes in product mix?
A8. A CMA is required for any material change in business. Though it’s possible that a change in product mix might not require a CMA, one will be required if the result is a material change to your firm’s business. For example, such a change in product mix would require a CMA (and prior FINRA approval) if it removed or modified a membership agreement restriction; caused your firm to become a market-maker, underwriter or dealer for the first time; or if the new products required a higher net capital. A CMA may also be required if there are changes to the size of your firm, including the number of associated persons and branch offices. When considering such changes, please review Rule 1017 carefully. If you have additional questions, you should contact your FINRA District Office or Coordinator. Q9. Can the filing of a Form BD amendment qualify as notice to FINRA of a CMA event? A9. Receipt of a Form BD amendment does not constitute “notice” under the NASD Rule 1010 Series. If FINRA Distr
