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 District Office staff learns of a change in ownership in this way, it will send a letter to the firm stating that it is required to comply with NASD Rule 1017(a) and has failed to provide at least 30 days prior written notice. Upon receipt of notice and an application, the clock will begin to run in terms of when FINRA will issue a written decision, in accordance with NASD Rule 1012(a).
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