A change, an annual review and a direct regulatory request trigger separate deadlines. One year-end task does not replace all three.

What the primary record establishes

FINRA Rule 4517 requires firms to report and maintain required contact information through the prescribed system. Changes must be updated promptly and no later than 30 days afterwards. FINRA Rule 4517 ↗

The annual review is due within 17 business days after calendar-year end. A FINRA request requires a prompt response within 15 days, unless staff agree to a longer period. FINRA Rule 4517 ↗

What the distinction changes

These are three triggers, not three alternatives. Completing the annual review does not excuse leaving an intervening contact change unreported.

The rule also uses business days for the annual review while the other quoted periods are stated as days. A workflow should preserve that distinction instead of hard-coding one generic timer.

What to check before drawing a conclusion

Operational evidence can connect the change date, reviewer and submission confirmation. An up-to-date internal address book alone does not establish that the regulator’s record was updated.

This is an existing rule, not a new October requirement. The useful control is a maintained process that survives staff turnover and routes requests to a named owner, with the precise trigger visible in its record.