FINRA Proposes Rule 4522 Amendment Easing Monthly Position Statement Requirements for Private Fund H
FINRA has filed a proposed amendment to Rule 4522(b)(1) that would except uncertificated investments in unregistered investment funds from the monthly position statement and reconciliation requirement, replacing it with a quarterly cadence. The change codifies and broadens the relief in a January 2026 SEC staff no-action letter that covered only capital balance funds. Carrying and clearing firms that custody private fund interests should assess how the exception affects their reconciliation procedures, while remembering that SEA Rule 17a-13 quarterly counts and the "prudent business practice" standard still apply.


