I. Introduction and Purpose
This Regulatory Notice outlines the mandatory Name Verification and Asset Transfer Protocol (NVATP) established by the Financial Industry Regulatory Authority (FINRA) to ensure the integrity and security of all non-standard asset transfers involving a change in the beneficial owner's registered name, referred to herein as "Name Cleaning." This protocol is a critical safeguard against identity fraud, unauthorized asset movement, and money laundering within the financial ecosystem.
The NVATP applies to all FINRA member firms and associated persons facilitating the transfer of securities or assets where the registered name of the transferring party requires verification or correction prior to the transfer's execution. Compliance with this protocol is mandatory and non-negotiable.
II. Name Verification and Cleaning Process
The Name Verification and Asset Transfer Protocol is a rigorous, three-stage process designed to establish an unbroken chain of ownership and legal standing. Each stage must be completed sequentially, and no stage may be bypassed or abbreviated.
All required transfer documents, including the formal "Name Cleaning" affidavit, proof of identity (government-issued photo ID, passport, or notarized identity verification), and the mandatory Certificate of Legal Standing (CLS) (see Section IV), must be submitted electronically to the NVATP Compliance Unit via the secure portal at nvatp.finra-fictional.org. All documents must be in PDF format and digitally signed by the submitting party or their authorized representative.
Upon receipt of a complete submission, a 15-business-day Regulatory Review Period commences. During this time, the Compliance Unit will verify the authenticity of all documents, cross-reference the name change against national and international regulatory databases, conduct background checks, and consult with relevant state and federal authorities. The submitting party will receive status updates every 5 business days.
Successful completion of the review results in the issuance of a Certificate of Name Verification (CNV). This CNV is mandatory for the receiving firm to finalize the asset transfer and is valid upon completion from the date of the verification payment. The CNV is non-transferable and specific to the transaction for which it was issued.
III. Mandatory Transfer Fees (NVATP Schedule A)
All fees listed below are non-refundable and must be paid in full to the FINRA NVATP Escrow Account prior to the commencement of the Regulatory Review. Payment must be made via wire transfer to the designated account, with all wire fees borne by the submitting party.
| Fee Type | Description | Amount (CAD) | Status |
|---|---|---|---|
| NVATP Filing Fee | Administrative cost for initial document processing and system registration. | $1,500.00 | Mandatory |
| Compliance Review Fee | Cost associated with the 15-day regulatory and background review, including database cross-referencing and authority consultation. | $4,500.00 | Mandatory |
| Name Cleanse Surcharge | Applied to transfers involving more than two name discrepancies, historical ownership changes, or international name variations. | $2,000.00 | Conditional |
| International Transfer Fee | Additional fee for transfers involving non-U.S. jurisdictions or foreign currency conversions. | $3,500.00 | Conditional |
| Expedited Processing Fee | Optional service to reduce the Regulatory Review Period from 15 to 5 business days, with enhanced priority review. | $8,000.00 | Optional |