How to File an Extension of Time With FINRA

Summary
How to Access REX Online
Reason Codes
Required Information by Extension Type
Examples of Comments for Exceptions
Workflow after Extensions are Submitted
Frequently Asked Questions
Filing using Batch Process
Holiday Margin Extension Schedule
References
Contact Information

1. Summary

FINRA Rule 4230(a) requires clearing firms for which FINRA is the designated examining authority pursuant to SEA Rule 17d-1 to submit requests for extensions of time as contemplated by Regulation T of the Board of Governors of the Federal Reserve System (Regulation T) and SEA Rule 15c3-3(n) to FINRA for approval. Firms are also required to file with FINRA their request for extensions of time to satisfy margin deficiencies pursuant to FINRA Rule 4210. FINRA has implemented an automated system for the receipt and processing of such extensions-of-time requests (the REX system).The Federal Reserve Board's Regulation T and SEC Rule 15c3-3 provide for the possibility of extensions of credit by broker-dealers to investors when they have not promptly paid for a securities transaction.

Specifically, Regulation T gives an investor a maximum of four business days to pay for securities purchased in a cash or margin account. If payment due exceeds $1,000 and is not received by the end of this time period, the broker-dealer must either liquidate the position or apply for and receive an extension from its designated examining authority, such as FINRA.

SEC Rule 15c3-3 pertains to a customer's obligations when securities are sold, other than short sales. The rule requires that if a security sold long has not been delivered within 10 business days after the settlement date, the broker-dealer must either buy the customer in or apply for and receive an extension from its designated examining authority.

Firms must file Regulation T, SEC Rule 15c3-3 and 4210 extension of time requests via FINRA's Regulatory Extension (REX) system or via Batch.

Once a firm has a transaction that requires an extension of time to be filed to comply with Regulation T, SEC Rule 15c3-3 or 4210, the below methods and documents should be used as a resource to submit the extension to FINRA.

2. How to Access REX Online

Members are able to use one single sign-on to access both the production and Customer Test Environment (CT). Firms are encouraged to have new joiners use CT for training purposes.

Please note that the landing page of the REX system will have important reminders for firms submitting extensions of time. We encourage users, even firms using batch, to frequently review the page to stay current with important notices for extension filing.

3. Reason Codes

The reason code list provides details on the different reason codes available for filing an extension of time. Firms should find the reason code that best describes why more time is needed.

To assist users in select the correct reason code, please see the Reason Code Summary Grid

The summary grid includes:

Description of each reason code
When to submit first extension by reason code
Number of days permitted
Limits per reason code

4. Required Information by Extension Type

Below are the required fields that a firm must populate when submitting Regulation T, 15c3-3 or 4210 extensions of time.

Regulation T Extensions – required fields are marked with an asterisk (*)

General Information

* Reason Code Options – Regulation T (001 through 021; see extension reason codes for more details)

*Original Request Date – Should equal date of the submission. On a follow-on (subsequent or second, etc.) extension request for a given transaction, original request date must reflect the date of the original filing.

*Days Requested – Count from the original request date, refer to the reason code grid for the number of days allowed per extension reason code.

Security Information

*Trade Date – In cases where the trade is booked “as of”, resulting in the extension of time request being past the date it should have been requested. Follow this procedure:

Do not use the original trade and settlement date.
Use the date the trade was booked as both the trade and settlement date.
The extension request should be filed the day after the as of trade was booked.
Detailed explanation must be included in the extension comment field.
(Note: without a detailed explanation, the extension will not be granted.)
Send an email to [email protected] with:
Subject line: As of trade extension request
Body: Extension reference number
Extensions filed using the above procedure will be denied by default, and FINRA will review all details provided before approving.

*Settlement Date

*Product Code – (Equity, Bond, Derivative, Mutual Fund or Option).

*Security identifier – (Security lookup tool available to populate cusip and symbol) if security is not found, select Security not found and provide a CUSIP or symbol.

*New Issue – (Yes or No) If yes is selected, the extension should be filed on Settlement +4 (changing Settlement + 3 due to the settlement cycle changing on May 28, 2024 to T+1)] days.

*Dollar Amount – The total dollar amount of credit extended to this account for the specified trade date. On a follow-on (subsequent or second, etc.) extension request for a given transaction, the total dollar amount must not exceed the value on the original request.

*Share Quantity – In the case of multiple transactions for same customer on same date, enter the aggregate number of shares or contracts.

Broker Information

*Correspondent Firm Type has specific required fields based on the selection (Domestic, Foreign, None)

Domestic (will require):
- *Correspondent CRD (lookup feature is available and will populate correspondent CRD and Correspondent Name)
- *Branch/Correspondent Branch CRD (lookup option available, must provide branch CRD and city and branch state)
- *Customer Contact CRD Type (Registered Rep or Self Directed)
  - *Registered Rep option will require:
    - *Reg Rep CRD Number
- Foreign (will require)
  - *Foreign IB Name
None (Will require)
- *Branch/Correspondent Branch CRD (lookup feature is available, must provide branch CRD and city and branch state)
- *Customer Contact CRD Type (Registered Rep or Self Directed)
  - *Registered Rep option will require:
    - *Reg Rep CRD Number

Customer Info

*Customer Type – (Domestic Company, Domestic Individual, Foreign Company, Foreign Individual).

* SSN/TIN – Last 4 Digits – only for Domestic Company or Domestic Individual.

*Account Type (Cash or Margin)

*Account Number

*First Name

*Last Name

Comment – This field is required for Regulation T Reason Codes 016 and 021 extensions and is optional otherwise (up to 255 characters available).

Once all required details are provided the firm has 3 options:

Save as Draft (will not validate, do not leave items in draft overnight, submit or delete by the end of the day);
Print Preview and;
Submit – If critical fields are missing the extensions will generate “Validation Errors” “This field is required.” The missing field in the form is highlighted.

Select Issues/Feedback to open an email addressed to [email protected]; [email protected]

15c3-3(n) Extensions – required fields are marked with an asterisk (*)

15c3-3(m)

General Information

*Rule Type – Select (m).

*Reason Code Options – (040 through 052; see extension reason codes for additional details).

*Days Requested – Count from the original request date, refer to the reason code grid for the number of days permitted per extension reason code.

Security Information

*Trade Date

*Settlement Date

*Product Code – (Equity, Bond, Derivative, Mutual Fund, Option).

*Security identifier – (Security lookup tool available to populate cusip and symbol) if security is not found select Security not found and provide a CUSIP or symbol.

*Dollar Amount – In the case of multiple transactions in the same security on the same date, enter the aggregate dollar amount. On a follow-on (subsequent or second, etc.) extension request for a given transaction, original request date must reflect the date of the original filing.

*Share Quantity – In the case of multiple transactions in the same security on the same date, enter the aggregate number of shares or contracts.

Broker Information

*Correspondent Firm Type has specific *required fields based on the selection (Domestic, Foreign, None)

Domestic (will require)
- *Correspondent CRD (lookup feature is available and will populate correspondent CRD and Correspondent Name)
- *Branch/Correspondent Branch CRD (lookup option available, must provide branch CRD and city and branch state)
- *Customer Contact CRD Type (Registered Rep or Self Directed)
  - *Registered Rep option will require:
    - *Reg Rep CRD Number
Foreign (will require)
- *Foreign IB Name
None (Will require)
- *Branch/Correspondent Branch CRD (lookup feature is available, must provide branch CRD and city and branch state)
- *Customer Contact CRD Type (Registered Rep or Self Directed)
  - *Registered Rep option will require:
    - *Reg Rep CRD Number

Customer Info

*Customer Type (Domestic Company, Domestic Individual, Foreign Company, Foreign Individual).

*SSN/TIN – Last 4 Digits only for Domestic Company or Domestic Individual.

*Account Type – (Cash or Margin.)

*Account Number

*First Name

*Last Name

*Comment – This field is required for 15c3-3(m) Reason Codes 046, 050 and 051 extensions and is optional otherwise (up to 255 characters available).

Once all required details are provided the firm has 3 options:

Save as Draft – (will not validate, do not leave items in draft overnight, submit or delete by the end of the day);
Print Preview and
Submit - If critical fields are missing the extensions will generate “Validation Errors” “This field is required.” Missing field in the form is highlighted.

Select Issues/Feedback to open an email addressed to [email protected]; [email protected]

15c3-3(h),(d)(2) and (d)(3)

General Information

*Rule Type – Select (h), (d)(2) or (d)(3).

*Reason Code Options – (070 through 080; see extension reason codes for additional details).

*Days Requested – Count from the original request date, refer to the reason code grid for the number of days permitted per extension reason code.

Security Information

*Trade Date

*Settlement Date

*Product Code – (Equity, Bond, Derivative, Mutual Fund, Option).

*Security identifier – (Security lookup tool available to populate cusip and symbol) if security is not found, select Security not found and provide a CUSIP or symbol.

*Dollar Amount – Current Contract Value.

*Share Quantity

Firm to Firm Information

*Deficiency Date – The deficiency date should be one business day prior to the extension request date for (d)2 or (d)(3) requests. Deficiency date is not Applicable for (h)filings.

*Payable Date – Only applicable for (d)(3) filings.

*Receivable From – Only applicable for (d)(3) filings.

*Contra ID Code – Only applicable for (d)(2) filings.

*Contra ID – Only applicable for (d)(2) filings.

*Comment – This field is required for 15c3-3(h), (d)(2) and (d)(3) Reason Code 080 extensions and is optional otherwise (up to 255 characters available).

Once all required details are provided the firm has 3 options:

Save as Draft – (will not validate, do not leave items in draft overnight, submit or delete by the end of the day);
Print Preview and;
Submit – If critical fields are missing the extensions will generate “Validation Errors” “This field is required.” Missing field in the form is highlighted.

Select Issues/Feedback to. open an email addressed to [email protected]; [email protected]

15c3-3 (d)(4)

General Information

*Rule Type – Select (d)(4).

*Reason Code options – (073, 077 and 080; see extension reason codes for additional details).

*Days Requested – Count from the original request date, refer to the reason code grid for the number of days permitted per extension reason code.

*Deficit Date – Date of Deficit must be within 32 days of Request date (i.e., 30 calendar days + 1 or 2 Business days).

Security Information

*Product Code – (Equity, Bond, Derivative, Mutual Fund, Option)

*Security identifier – (Security lookup tool available to populate cusip and symbol) if security is not found, select Security not found and provide a CUSIP or symbol.

*Dollar Amount – The total dollar amount must not exceed the value on the original request.

*Share Quantity – In the case of multiple deficit locations (PAB, Firm, Customer, Non-Customer) the share quantity should be the sum of all allocated quantities.

Deficit Allocation Information

*Proprietary Account of Broker Dealer (PAB) – Allocation Quantity

*Firm Inventory – Allocated Quantity

*Customer – Allocated Quantity

*Non-Customer – Allocated Quantity

*Comment – This field is required for 15c3-3 (d)(4) Reason Code 080 extensions and is optional otherwise (up to 255 characters available).

Once all required details are provided the firm has 3 options:

Save as Draft – (will not validate, do not leave items in draft overnight, submit or delete by the end of the day);
Print Preview and;
Submit – If critical fields are missing the extensions will generate “Validation Errors” “This field is required.” Missing field in the form is highlighted.

Select Issues/Feedback to. open an email addressed to [email protected]; [email protected]

4210 Extensions – required fields are marked with an asterisk (*)

Below are the required fields that a firm must populate when submitting Regulation T, 15c3-3 or 4210 extensions of time.

Regulation T extensions (required fields)

General Information

*Reason Code Options – (060 through 069; see extension reason codes for additional details).

*Date Extension Filing is Due – must reflect the date of the original filing.

*Days Requested – Count from the Date Extension Filing is Due, refer to the reason code grid for the number of days permitted per extension reason code.

Mark to Market Loss or Deficiency Information

*Date of Mark to Market Loss or Deficiency – The date the mark to the market loss or deficiency, as applicable, occurred.

*Mark to Market Loss or Deficiency Amount – The current market to market loss or deficiency amount, as applicable.

*Account Number – The Counterparty’s account number.

*Account Name – The Counterparty’s name.

*Is the counterparty a US B/D? (Yes or No) if yes provide

*Broker/Dealer CRD

*B/D Name

*Is the extension request on behalf of a US correspondent? If yes provide

*Correspondent CRD

*Correspondent Name

*Comment – This field is required for 4210 Reason Codes 063, 067, 068 and 069, extensions and is optional otherwise (up to 255 characters available).

Once all required details are provided the firm has 3 options:

Save as Draft – (will not validate, do not leave items in draft overnight, submit or delete by the end of the day);
Print Preview and
Submit – If critical fields are missing the extensions will generate “Validation Errors” “This field is required.” Missing field in the form is highlighted.

Select Issues/Feedback to open an email addressed to [email protected]; [email protected]

5. Examples of Comments for Exceptions

In the event a firm needs an additional extension for exceptional circumstances, reason codes (016, 021, 046, 050, 051, 063 or 080) should be used, based on Rule Type and a detailed comment should be included in the extension filing. Below are some examples of the details that would be helpful during our manual review. Having detailed commentary will prevent additional emails to the firm for more information.

* Corporate Action/Dividend Receivable

Supply details on the corporate action and include any critical dates that is resulting in the need for an extension.

* Contingent Value Rights (CVR)

Indicate it is a CVR in the comment field and supply details on any critical dates that is resulting in the need for an extension.

* No Market/Unable to Buy-in

If no market to buy-in, firm should supply a list of days the desk attempted to buy-in.

* Chilled for Delivery

If chilled, firm should comment if DTC has indicated if the chill or freeze is short term to facilitate a distribution, merger, split, etc. or has no current timetable.

*Physical Transaction/Private Placement

Status of paperwork completion from the parties involved, including:
- Transfer Agent Status
- Custodian Status
- Estimated date of completion

* Ongoing Reconciliation Discrepancies/Short Security Differences

Status update from business unit or operations to resolve discrepancy with contra or custodian.
Contra/Custodian Status.
Estimated date of completion.

*Contra /Custodian Short/Fail to Receive

Buy-in issued and the desk attempted or bought-in on the following days: 9/1/2025, 9/8/2025, 9/20/2025
(Please note that the firm should be attempting to buy-in on a frequent basis)

*Broker-dealer Segregation Deficit for More than 30 Calendar Days ((d)(4) only)

Status update to resolve discrepancy with contra or custodian as well as the marketability of the security.

*Human Error

Please provide details on the human error that resulted in the firm not filing on a timely basis.
Explain the controls that will prevent this from re-occurring.

*System Error

Please provide details on the system error that resulted in the firm not filing on a timely basis.
Explain the controls that will prevent this from re-occurring.

*Natural Disasters, Acts of God, or Other Abnormal Conditions

Area affected by the Natural disaster or Act of God that is preventing completion. Specify if the client or branch office is impacted and include their location.

6. Firm Expected Workflow After Extensions Are Submitted

Firms are expected to review the status of each extension of time request after it is submitted to FINRA.

Extensions are processed and validated with our extension rules in approximately 15 minutes and not in real-time. After system validation, each extension will have a status of either Granted, Pending, Denied or Draft.

Firms should have a process to validate that all submitted extensions have been processed and received a Granted status. Firms can view this information directly on the filing cabinet or retrieve reports through the online REX system interface and on the firm's daily extension report provided by FINRA. Any extension of time request that is denied due to incomplete or inaccurate information is eligible for reconsideration if corrected and resubmitted via the online REX system within two business days.

Below is a brief explanation of the status messages and the action a firm should take.

Firm next steps:

Granted - No further action.
Pending - The extension requires Credit Regulation manual review and approval. After our review, we will either Grant or Deny the extension. If the extension is denied, we will include a detailed comment for the denial with next steps the firm can take.
Denied - Extensions will be denied based on failing Credit Regulation extension rule validations or our manual review. The disposition comment will include details on any extension rule failure or manually identified issues. The firm should review and make the necessary amendments to the extension. Once amended, the extension will re-process for validation with the updated information.
Draft – This only applies to extensions filed via the batch process. Draft filings are not granted, pending or denied. Extensions in draft are incomplete and require the firm to update and re-submit or delete. Draft items can be identified by exporting the batch draft report in the filing cabinet. Details on the changes needed to complete the process will be included in the report.

7. Frequently Asked Questions

All changes in filing time frames due to the settlement cycle changing on May 28, 2024 to T+1 will be noted as such, [T+2] or[T+3].

1. Why is my extension being denied?

Refer to the filing cabinet to review the reason for the denial.

2. If an extension is denied, do I need to submit a new extension of time with the updated information?

No. You do not need to submit a new extension of time and can amend the denied extension within two business days. The system will not accept any amendments after this grace period.

3. Will my extension process be impacted because of T+1?

Yes. Please review the extension code reference guide for details on the reason codes that will change because of T+1.

4. If a Regulation T extension is filed with 7 calendar days to expiration and there is a market holiday during that extension period, does the customer get an additional day to pay for their purchase?

No, except when the extension expires on a market holiday. In that case, the extension will expire on the next business day.
For example:

On Tuesday, Jun 27, FINRA grants a 7-day extension of time to pay for a trade. Tuesday, July 4 is a market holiday. The extension expires on Wednesday, July 5
On Monday, July 3, FINRA grants a 7-day extension of time to pay for a trade. Tuesday, July 4 is a market holiday. The extension expires on Monday, July 10

5. Do we need to send an email to FINRA to let them know we are withdrawing an extension?

No. You can withdraw extensions directly on the UI within two days after submission.

6. Should I review all extensions submitted to ensure all have been granted?

Yes. Firms are expected to review all extensions submitted. To ensure that all validations have been passed and received a granted status. Firms can view the status directly and pull reports from the filing cabinet. For more details, please see Question 7. “What extension details can a firm retrieve directly from the filing cabinet?

7. What extension details can a firm retrieve directly from the filing cabinet?

Category of extensions submitted (All, Batch, UI, Draft, Rejection Reports, Disposition changes and Finalization).
Date range.

The data can be exported into a CSV file. The file will include all extension details entered by the firm as well as expiration date of extension, disposition status and any error messages that led to a denied or draft filing.

Please note, firms can export extension of time requests using the filing cabinet to a csv file allowing further customization and filtering.

8. When multiple purchases are executed for the same customer account on the same trade date requiring a Reg T extension, what information is required for the amount, quantity, and issue symbol/CUSIP fields?

The amount field should be populated with the net debit created on that trade date. If a follow-on extension request is made, the total dollar amount must not exceed the value on the original request. The quantity and issue symbol/CUSIP fields need only be populated with the details from one of the transactions, regardless of whether different securities or issuers are involved.

9. Do I need to file a Reg T extension if the amount owed is $1,000 or less in the cash account?

No, you do not need to file an extension of time if the aggregate amount owed by the customer is $1,000 or less.

Please note that the $1,000 de minimis amount is not applied by individual trades. For example, if a customer owed $200 for a purchase of ABC stock in the cash account on Monday and on Tuesday purchased $900 of XYZ stock increasing the amount owed to $1,100, an extension must be filed for $200 purchase of ABC on Thursday, or the trade liquidated as the aggregate amount owed exceeds $1,000.

10. Why is FINRA not approving additional time on exceptional reason code extensions for 15c3-3 (d)(4) short positions for Municipal securities or Certificate of Deposit (CD)?

FINRA will not grant any exceptional reason code extensions for 15c3-3 (d)(4) deficits when a member firm has a deficit in a Municipal Security or Certificate of Deposit (CD).

Firms need to be mindful of the additional concerns that arise when customer long positions in tax-exempt municipal securities allocate to short positions. Consequently, a customer seeking tax-exempt interest may be receiving substitute interest from the firm, which may in fact be taxable. In the case of CDs that firm is short, the CD may not be covered by FDIC insurance.

Please see reference Regulatory Notice 15-27 for more details.

11. Will clearing firms have access to FINRA's Central Registration Depository (CRD) database in order to retrieve the representative or branch CRD numbers of their correspondent firms?

No. A clearing firm will only be able to access its own CRD numbers through the CRD database. If a clearing firm is filing an extension of time request on behalf of a correspondent firm, the clearing firm must obtain the applicable CRD numbers from the correspondent firm.

12. In the quantity field, how should fractional shares be handled?

Fractional shares cannot be entered into the quantity field. Firms must round up and input a whole number. For example, a purchase of 0.2 shares, should be entered as 1 share.

13. For 15c3-3(d)2 or (d)3 extension requests, should the deficiency date field be one or two business days prior to the extension request date?

The deficiency date should be within two business day prior to the extension request date.

14. How are extended settlement dates for foreign transactions handled?

Use reason code 008 when submitting extensions that are filed under Reg T for foreign transactions with settlement date of three business days through and including the 34th calendar day after trade date, should be:

If the settlement date is less than or equal to T+3 [T+2] business days, the request shall be made on T+4 [T+3] business days, or

If the settlement date is greater than or equal to T+4 [T+3] business days, the request shall be made on the earlier of one business day after the date on which settlement is required to occur by the rules of the foreign securities market or T+35 calendar days.

15. What is the cut-off time for extension requests to be submitted?

Firms should submit extension requests no later than 11:30 p.m. on the business day that they are due. Requests submitted after 11:30 p.m. may not be applied until the next business day.

16. If a firm submits extension requests via a batch process, can the firm also submit extension requests directly via FINRA Gateway?

Yes. Firms will be able to submit extensions online regardless of how it normally submits extensions.

17. Is a firm limited to one batch submission per day?

No. There is no specific limit to the number of batch extensions a firm may submit during a business day.

18. How will my firm be billed for extensions that are submitted?

Firms will be billed on a quarterly basis for all extensions whether such requests are granted or denied. Pursuant to Section 8 of Schedule A to the FINRA By-Laws, the service charge for processing extension requests is currently $4 per request.

19. Our customer or branch location is not able to meet its obligation because of a natural disaster. How do we file for such an extension?

In the event of a natural disaster that impacts a customer or branch, member firms may use Natural Disaster reason codes, 016 for Regulation T, 051 for 15c3-3, and 063 for 4210, extensions for branches or customers impacted by a natural disaster. If a firm or customer is affected by the Natural Disaster that is preventing the satisfaction of the obligation, the firm must include a comment when submitting the extension of time and specify if the customer or branch office is impacted and include their location. Firm should reference the extension code reference guide for more details.

20. When and how will a firm be able to receive reports for submitted extension requests?

Firms will be able to view all their extension requests from the filing cabinet, usually in one to two minutes, after submission regardless of how they submit such extensions. Firms that use a batch process using Secure File Transfer Protocol (SFTP) will receive their reports via SFTP. Firms using a service provider will not receive reports directly from FINRA through SFTP; they will need to access their reports through their service provider.

8. Filing Using the Batch Process

Firms with a high volume of filings may find that batch submission is more efficient than manually submitting individual entries to FINRA using FINRA Gateway. Any firm interested to learn more about submitting extensions using the batch process should contact [email protected] for more information.

9. Holiday Extension Filing Schedule

To help with filing extensions on the correct day during exchange or bank holidays, please see:

Margin Extension Schedule for Holidays

10. References

https://www.finra.org/rules-guidance/notices/18-30

https://www.finra.org/rules-guidance/notices/18-07

https://www.finra.org/rules-guidance/notices/17-12

https://www.finra.org/rules-guidance/notices/15-27

https://www.finra.org/rules-guidance/notices/14-13

https://www.finra.org/rules-guidance/notices/10-45

https://www.finra.org/rules-guidance/notices/10-28

https://www.finra.org/rules-guidance/notices/10-08

https://www.finra.org/rules-guidance/notices/08-32

https://www.finra.org/rules-guidance/notices/06-62

11. Contact Information

Any questions on filing for extensions contact:

[email protected]

Theresa Reynolds at (646) 315-8567

Joseph David at (646) 315-8444

For technical assistance with log-in, batch filing or other issues with FINRA Gateway, please contact the FINRA Call Center at (800) 321-6273, Option 3, and specify your issues. The call center will route your query to the relevant technology support team.