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Can an entity who is not a member of FINRA file sales communications with the Advertising Regulation Department?

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Can an entity who is not a member of FINRA file sales communications with the Advertising Regulation Department?

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Only a member of FINRA may file sales communications. However, a non-member may arrange with a FINRA member to file such material on the non-member’s behalf. The member through whom the communication is filed is sent the review letters and assumes compliance responsibilities.

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