A practical review connects the disclosure requirement to delivery records, ownership of the process and the rule’s stated exceptions.

What the primary record establishes

FINRA Rule 2267 generally requires written BrokerCheck contact and brochure information once per calendar year. Electronic delivery is permitted. FINRA Rule 2267 — Investor Education and Protection ↗

The text specifies exceptions for certain introducing arrangements and for qualifying carrying agreements. Its scope must be checked before assigning responsibility. FINRA Rule 2267 — Investor Education and Protection ↗

What the distinction changes

WFN interpretation: a disclosure process needs an identifiable recipient group and a responsible team. A link stored in an internal manual alone does not show what any particular customer received.

A useful delivery record connects the version of the text, the recipient population and the delivery date. That allows an operational reviewer to distinguish missing content from a failure to reach the intended accounts.

What to check before drawing a conclusion

When firms share account-servicing duties, document which arrangement actually applies. Do not infer an exemption merely from a commercial description such as introducing broker without checking the conditions in the rule.

BrokerCheck can support a customer’s investigation, while the annual information process has its own delivery question. Review those two tasks separately and read the full rule for applicability; this explainer describes an existing US requirement rather than a new October enactment.