On September 22, 2023, FINRA filed a proposed rule change for immediate effectiveness to extend temporary Supplementary Material .17 (Temporary Relief to Allow Remote Inspections for Calendar Years 2020, 2021, 2022, and 2023) under FINRA Rule 3110 (Supervision) to include calendar year 2024 inspection obligations through the earlier of:

Rule 3110.17 provides that member firms may satisfy their inspection obligations under Rule 3110(c) remotely, without an on-site visit to the office or location. Firms who opt to conduct calendar year inspections remotely must comply with the additional requirements provided under Rule 3110.17.

The relief under Rule 3110.17 was adopted as part of FINRA's response to the COVID-19 pandemic, and originally covered only 2021 and 2022 calendar year inspections. However, FINRA has since extended the expiration of the temporary relief several times as it attempts to establish a remote inspections pilot program. In April 2023, FINRA withdrew its original proposed rule change to establish the pilot program and filed a new proposal that included certain clarifying changes (see Legal Update, FINRA Reproposes Remote Inspections Pilot Program). The SEC currently has until December 30, 2023, to act on FINRA's most recent proposed rule change.