Regulatory Reporting Requirements Wednesday, May … · Debra A. Roth is an executive director and Head of the Compliance Regulatory Group at Morgan Stanley, where she is responsible

© 2016 Financial Industry Regulatory Authority, Inc. All rights reserved. 1

Regulatory Reporting Requirements Wednesday, May 25 10:00 a.m. – 11:00 a.m. This session focuses on regulatory requirements and firm practices related to reporting and disclosure. FINRA panelists highlight key reporting requirements including requirements for maintaining Forms U4 and U5, customer complaint reporting obligations, and FINRA Rule 4530 reporting obligations. Moderator: Anthony Cavallaro Senior Vice President FINRA Office of Fraud Detection and Market Intelligence Panelists: Monica Daggs

Senior Vice President and CFS AML Compliance Officer Sorrento Pacific Financial, LLC and CUSO Financial Services, LP Mario DiTrapani Vice President FINRA Registration and Disclosure

Mark D. Knoll Attorney Bressler, Amery & Ross, P.C.

Debra Roth Executive Director and Head of the Compliance Regulatory Group Morgan Stanley


Regulatory Reporting Requirements Panelist Bios: Moderator: Anthony Cavallaro is a senior vice president and the head of the Central Review Group of FINRA’s Office of Fraud Detection and Market Intelligence. He is responsible for managing two units that review and investigate regulatory filings, complaints and other matters received regarding violations of SEC and FINRA rules and regulations. Mr. Cavallaro reports to the Department’s Executive Vice President. Prior to his current role, Mr. Cavallaro was a vice president in the Member Regulation Department and also served in the Enforcement Department of FINRA where he managed two units that investigated and prosecuted violations of securities laws and regulations. Mr. Cavallaro was a vice president at the New York Stock Exchange and began serving at FINRA when NYSE Member Regulation and Enforcement consolidated with NASD to form FINRA in 2007. Prior to joining the NYSE in 1997, Mr. Cavallaro was an Assistant District Attorney in the New York County District Attorney’s Office where he was responsible for investigating and prosecuting various criminal matters including white-collar cases. Mr. Cavallaro received his law degree from St. John’s University School Law and a B.S. in finance from Fordham University, College of Business Administration. He is a military veteran and retired with the rank of major after 20 years of service in the US Army Reserve. Panelists: Monica Daggs is Senior Vice President, Implementations and Trading at Sorrento Pacific Financial, LLC and CUSO Financial Services, LP (SPF & CFS). Her current role includes oversight of the firms’ trading services, implementations, internal audit, and regulatory compliance. Ms. Daggs has more than 15 years of industry experience in Operations, Compliance, Legal, and Internal Control with a strong background working with financial institutions and independent contractor models. Having joined SPF & CFS in 2005 to oversee the internal control and supervisory structure of the firm, Ms. Daggs has also directly overseen Compliance, Internal Control and Registration. Prior to joining SPF & CFS, Ms. Daggs was responsible for day-to-day management of advisory compliance for Linsco/Private Ledger with a focus on system automation and internal surveillance. She has served as the FINRA District 2 Representative for large firms and has served on the FINRA Regulatory Advisory Committee. Ms. Daggs received her bachelor degree from the University of Illinois. Mario DiTrapani is Vice President, FINRA, Registration and Disclosure (RAD), which is responsible for the operation of the Central Registration Depository (Web CRD®), the Investment Adviser Registration Depository (IARDTM) and FINRA BrokerCheck®. His current management responsibilities encompass the following RAD units: Regulatory Services and Operations, Regulatory Review and Disclosure, Quality Control and Communications. Mr. DiTrapani began his tenure with FINRA in 2006 as part of NASD, which consolidated with the NYSE Member Regulation in 2007 to form FINRA. Mr. DiTrapani also serves as FINRA’s Executive Sponsor for FINRA’s Latino Affinity Network, an employee resource group designed to promote diversity and inclusion. He also currently serves on the Securities and Insurance Licensing Association’s (SILA) Board of Directors as a Regulatory Advisor. Prior to joining FINRA, he was Senior Vice President and Deputy Director of Compliance for UBS Financial Services Inc., where he oversaw registration, insurance licensing, regulatory reporting, outside accounts and outside business activities. Mr. DiTrapani also served as President of the Association of Registration Management (ARM). He has been a financial services industry professional for over 30 years and has served on various industry/regulatory committees focusing on registration and qualifications issues. Mr. DiTrapani holds a Bachelor of Business Administration degree in Finance and Investments from the Bernard M. Baruch College of the City University of New York. Mark D. Knoll is Partner in Bressler, Amery & Ross, P.C., located in New York, New York. Mr. Knoll’s practice focuses on counseling and defending broker-dealers, investment advisers and other financial institutions in regulatory enforcement, litigation and compliance matters. In his regulatory enforcement practice, Mr. Knoll has represented clients in matters before the SEC, FINRA, CFTC, CME, NFA and several state securities regulators involving a wide range of issues, including trading and capital markets, registration, complaint reporting, sales practice, supervision and operations. In his litigation practice, Mr. Knoll has represented issuers in both individual securities fraud and class-action matters, and represents broker-dealers in a wide variety of substantial arbitration and civil litigation matters. Finally, Mr. Knoll also counsels broker-dealer and investment adviser clients regarding all aspects of


their compliance programs, along with registration and reporting issues. Prior to joining Bressler, Amery & Ross, Mr. Knoll served as a director and counsel to the regional head of compliance for the Americas at Credit Suisse Securities (USA) LLC. Debra A. Roth is an executive director and Head of the Compliance Regulatory Group at Morgan Stanley, where she is responsible for coordinating and managing the firm's relationships with the SEC, CFTC, self-regulatory organizations, exchanges, and state regulators on behalf of both the institutional and retail broker-dealers. In this role, she supervises the firm's responses to regulatory examinations, inquiries, sweeps, surveys and ad hoc information requests. Prior to her current role, she oversaw the firm’s U.S. Registration Department, Employee Trading Group, Policies & Procedures Group and Examinations & Inquiries Group. Before joining the Compliance Department, Ms. Roth was the East Coast Head of Client Litigation, where her responsibilities included supervision of arbitrations, litigation and regulatory matters arising in the eastern United States as well as regulatory reporting functions nationwide. She was previously a partner in a New York City law firm where she focused on civil litigation and arbitration matters. She received her law degree from Brooklyn Law School and her bachelor’s degree from Purchase College, SUNY.

FINRA Annual Conference May 23–25, 2016 • Washington, DC

Regulatory Reporting Requirements

FINRA Annual Conference © 2016 FINRA. All rights reserved.

Moderator Anthony Cavallaro, Senior Vice President Office of Fraud

Detection and Market Intelligence, FINRA Panelists Mark D. Knoll, Attorney, Bressler, Amery & Ross Monica Daggs, Senior Vice President Trading and

Implementations, Certified Fund Specialist/AML Compliance Officer, CUSO Financial Services, LP Mario DiTrapani, Vice President Central Registration

Depository/Public Disclosure, FINRA Debra Roth, Legal and Compliance Division, Morgan Stanley

1

Panelists


Outline Forms U4/U5 and U6 FINRA Rule 4530 Handling and Reporting of Complaints Case Studies Q&A

2

Uniform Registration Forms Regulatory Reporting Requirements


Fundamentals of Responding to Forms U4/U5/BD questions Forms U4/U5 Customer Complaint Questions Form U5 – Disclosure Certification Checkbox Form U6 and Investigation Disclosures Form U4 – Other Business FINRA Rule 3110(e) Forms U4 & U5 Filing Tips

4

Topics of Discussion


Form U4 (Uniform Application for Securities Industry Registration or Transfer) Registered Representatives (“RRs”) have an obligation to:

– File a complete and accurate initial Form U4. – Amend their Form U4 within 30 days whenever an event occurs to render a previous response

inaccurate or incomplete. Events triggering Statutory Disqualification must be reported within 10 days.

Form U5 (Uniform Termination Notice for Securities Industry Registration) Broker-dealers have an obligation to:

– File a Form U5 upon termination of an RR. – Amend an RR’s Form U5 as needed, within 30 days whenever an event occurs to render

previous information inaccurate or incomplete.

5

Individual and Broker-Dealer Disclosures


Form BD (Uniform Application for Broker-Dealer Registration) • Like Forms U4 and U5, amendments must be filed within 30

days of an event rendering a previous response inaccurate or incomplete.

• Disclosure questions also apply to control affiliates and control persons.

• Unlike Forms U4 and U5, Wells Notice are not required to be reported on Form BD.

6

Individual and Broker-Dealer Disclosures


Forms U4 & U5 Customer Complaint Questions (14I & 7E) “Subject of” an arbitration or civil litigation – RRs are required to report sales practice

related claims made in arbitrations and litigations that do not name them as a party, but whose conduct is the cause of the claim.

All complaints involving forgery, theft, misappropriation or conversion of funds or securities are reportable, regardless of dollar amount.

Written customer complaints alleging a sales practice violation and damages of $5,000 or more are reportable. If no damages are alleged, it must be reported unless the firm can determine that the damages are less than $5,000.

Verbal customer complaints are only reportable if they result in settlement of $15,000 or more.

Settlement is the total amount paid to customer to resolve dispute – not just the RR’s contribution.

Customer complaints received by a regulatory authority and forwarded to the RR’s firm for response/handling follow the same reporting guidelines.

7


Form U5 Disclosure Certification Checkbox. By checking the box the firm certifies that:

– There is no additional information to be reported at this time; and – Details relating to Questions 7A, 7C, 7D and 7E have been previously

reported via Form U4 (firms cannot certify to 7B or 7F). – Firm acknowledges it will update information, as appropriate.

Use of the checkbox is optional. When providing explanations for reasons for terminations, firms

must provide enough information so the reader can understand the conduct that led to the RR’s termination and answer all disclosure questions accurately. See Regulatory Notice 10-39.

8

Form U5 Updates


Investigation Disclosure Reporting Page – Form U6 When FINRA’s Registration and Disclosure (RAD) staff learns that an RR was

issued a Wells Notice by FINRA, RAD will send an inquiry to the employing firm, or former firm if that is where the alleged misconduct occurred, requesting that the matter be reported on Forms U4/U5.

If timely and accurate reporting is made by the member, RAD will not file an Investigation DRP (Form U6).

RAD will file an Investigation DRP (Form U6) to report a FINRA Wells Notice if the member/RR: Does not report the matter within 30 days; Inaccurately describes the investigation on the filing; or Does not report sufficient detail.

Firms/RRs should provide enough information so that a person reviewing the record can understand the nature of the alleged misconduct.

9


Form U4 – Other Business RRs currently engaged in any other business as a proprietor, partner, officer,

director, employee, trustee, agent or otherwise, must disclose that on Form U4 (item # 13). Remember to include the following information: Name and address of the business, Whether or not it is investment-related, Nature of the business, Your position, title or relationship, Start date, Approximate number of hours/month devoted to the business, Number of hours you devote during securities trading hours, and Briefly describe your duties

For the purpose of Form U4, please exclude non-investment-related activity that is exclusively charitable, civic, religious or fraternal and is recognized as tax exempt.

12

FINRA Annual Conference © 2016 FINRA. All rights reserved. 11

FINRA Rule 3110(e) On July 1, 2015, FINRA Rule 3110(e) went into effect. The

rule requires firms to: • Ascertain by investigation the good character, business

reputation, qualifications and experience of an applicant • Review a copy of the applicant's most recent Form U5

(or NFA Termination Notice Form 8-T, if applicable) within 60 days • Establish and implement Written Supervisory Procedures (WSPs)

reasonably designed to verify the accuracy and completeness of the information contained in an applicant's initial or transfer Form U4 within 30 days – WSPs must, at a minimum, provide for a search of reasonably available

public records to be conducted by the member (or a third-party) to verify the accuracy and completeness of the information on the U4


Form U4 & U5 Disclosure Filing Tips Firms should check their queues in CRD regularly as disclosure obligations may be

triggered by events occurring away from the firm (i.e., U5 or U6). If a determination is made that 4530(d) filing does not meet the criteria for reporting

on U4/U5, firms should enter a comment (e.g., not U4/U5 reportable) in the 4530 notation field. This will eliminate unnecessary CRD inquiry letters.

Track and follow-up on disclosures with “pending” dispositions (“Individual - Disclosure Download Report”) and check the firm’s Report Center to monitor performance.

Safeguarding Personal and Sensitive Information – Do not put customer names or Social Security Numbers (or other personal or sensitive information) on Disclosure Reporting Pages (DRPs), except for those fields designated. These fields are suppressed from appearing in BrokerCheck®.

Familiarize yourself with FINRA Rule 1010 which permits a firm to file amendments to Form U4 disclosure without obtaining the RR’s manual signature, subject to certain conditions. See Regulatory Notice 09-40.

12

Reporting and Disclosure Requirements FINRA Rule 4530


Topics of Discussion

Rule 4530 Regulatory Reporting Requirements Reporting Internal Conclusions – 4530(b) Form U4 In Lieu of Filings

16


FINRA Rule 4530 The “Ten Disclosure Events.” Who must file: FINRA “Member Organizations.”

About whom: FINRA “Member Organizations.” Registered or non registered associated persons.

When: Within 30 days of reportable event.

17


FINRA Rule 4530 Rule 4530(a)(1)(A)-(H) requires a report when the firm

itself or an associated person is the subject of a listed event. Firms are required to report whenever the member or

person associated with the member: “Found” violations of securities(+) laws and rules

(4530(a)(1)(A)); Customer complaints involving allegations of theft or

misappropriation of funds or securities or of forgery (4530(a)(1)(B));

18


FINRA Rule 4530 Named as a defendant or respondent in any regulatory or SRO

proceeding alleging violations of securities(+) laws and rules (4530(a)(1)(C)); Individual denials of registration, expulsions, suspensions or

bars by regulators or SROs (4530(a)(1)(D)); Indictments, convictions, or guilty pleas to any felony or

misdemeanor involving securities or theft, robbery, forgery, misappropriation(+) (4530(a)(1)(E)); Principal, director, or officer of BD, IA, or Insco(+) that is

suspended, expelled, had its registration revoked or is convicted or pleads no contest to any felony (4530(a)(1)(F));

19


Settlements, Judgments, and Awards in connection with: Securities, commodities or financial related insurance arbitrations

or civil litigations; or Claims for Damages (written or oral) by a customer, broker or

dealer, that “relate to the provision of financial services or relate to a financial transaction” and that: – For individuals, exceed $15,000, and – For firms, exceed $25,000. – Note that amounts include attorney fees and interest. (4530(a)(1)(G))

FINRA Rule 4530

20


When firm or associated person is, or is involved in the sale of any financial instrument, the provision of investment advice or the financing of any such activities with any person who is, subject to “statutory disqualification” under the Exchange Act. (4530(a)(1)(H)).

FINRA Rule 4530 (cont’d)

21


Disciplinary Events Rule 4530(a)(2) requires a report when an “associated person” is the

subject of certain internal disciplinary action by the firm. Reportable internal disciplinary actions by the firm include: suspensions,

terminations, fines or withholding of compensation or of any other remuneration over $2,500 or “otherwise disciplined” in any manner that would constitute a “significant limitation” on the individual’s activities on a temporary or permanent basis.

A reduction in an associated person’s year-end bonus that exceeds $2,500 and is directly related to the disciplinary action by the firm, is reportable under 4530(a)(2).

22


Internal Conclusions Rule 4530(b) requires a report if the firm itself has concluded

or reasonably should have concluded that the firm or an associated person has violated any securities-, insurance-, commodities-, financial- or investment-related laws, rules, regulations or standards of conduct of any domestic or foreign regulatory body or self-regulatory organization. The rule does not require firms to report every instance of

noncompliant conduct.

23


Internal Conclusions (cont’d) With respect to violative conduct by a firm, the rule requires the firm to

report “only conduct that has widespread or potential widespread impact to the firm, its customers or the markets, or conduct that arises from a material failure of the firm’s systems, policies or practices involving numerous customers, multiple errors or significant dollar amounts.” Supplementary Material 4530.01.

With respect to violative conduct by an associated person, the rule requires the firm to report “only conduct that has widespread or potential widespread impact to the member, its customers or the markets, conduct that has a significant monetary result with respect to a member(s), customer(s) or market(s), or multiple instances of any violative conduct.” Supplementary Material 4530.01.

24


Internal Conclusions (cont’d) For violative conduct by an associated person, the reporting

obligation under paragraph (b) must be read in conjunction with the reporting obligation under paragraph (a)(2) of the rule. The firm need not report under paragraph (b) if the violative conduct results in disciplinary action covered under paragraph (a)(2). For purposes of compliance with the “reasonably should have

concluded” standard, FINRA will rely on a firm’s good faith reasonable determination. If a reasonable person would have concluded that a violation occurred, then the matter is reportable; if a reasonable person would not have concluded that a violation occurred, then the matter is not reportable.

25


Creation of a Rule 4530(b) Committee Includes representatives from Legal and Compliance.

Written supervisory procedures for 4530(b) Committee Process for escalation of matters to 4530(b)

Committee

Firm Practices and Procedures

26


Rule 4350(c) requires associated persons to report events to the firm “promptly.” Rule 4530(d) retains the quarterly complaint statistical

rule. Rule 4530(f) – Firms must file copies of certain

documents with FINRA (e.g., criminal documents, civil litigations, arbitrations that are not filed in FINRA).

Other FINRA Rule 4530 Provisions

27


Rule 4530(e) – Firms must file even if they file a Form BD amendment. Need not report under Rule 4530(a) or (b) if the

member files a Form U4 with the appropriate DRP box checked or a Form U5.

Form U4 In Lieu Of Filings

28


Firm Practices and Procedures Categories of Customers Identified in Supplementary

Material .08 Customer for purposes of paragraph (a)(1)(B) of the Rule. Includes any person, other than a broker or dealer, with whom

the firm has engaged, or has sought to engage, in securities activities. Customer for purposes of paragraph (d) is defined in two ways:

(1) if firm has engaged in securities activities – covers any written grievance; (2) if firm has sought to engage, only securities-related written grievance.

29

Reporting and Disclosure Requirements Handling and Reporting Complaints


Assess Customer Complaints

29

Recognition of Customer Complaints Training Compliance, Operations and branch personnel to recognize

complaints Training RRs to recognize and report customer complaints

Determine appropriate firm response Authorized parties for responses Written v. oral responses Timing of response Tracking ongoing resolution

Determine regulatory reporting requirements Uniform Form Reporting Requirements FINRA Rule 4530 (Disclosure and Complaint Filing)


Roles and Responsibilities

30

Internal handling versus outside assistance Supervision responsibilities Analyze for escalation Implications for Field and Home Office Possible need for Heightened Supervision Possible Identification of a Systemic Problem with a Product

Using complaint trends in compliance programs Audits, Inspections and supervisory systems Training programs

Complaint statistics


Regulatory Follow-Up Regulatory assessment Initial Assessment, Triage and Screening Routing to Appropriate Party for Further Review Districts / Enforcement / Market Regulation/OFDMI Trending and Analysis

Identifying Red Flags Prioritization and Response

Risk Based Examinations Examination Focusing Importance of Complaint Data Examination Focusing and Branch Office Selection

31


Regulatory Follow Up

32

Responding to regulatory requests Contact (FINRA) Author of Letter with Questions Complete Responses Generate Fewer Follow-up Requests Review and Consider all related records before responding

– Written Supervisory Procedures – Training Records – Branch Inspections, RR Attestations – Client files and related communications including emails – RR and RR’s Supervisor’s files

Conduct Interviews as necessary to learn the relevant facts

Reporting and Disclosure Requirements Case Studies


Examples and Explanations: Case Study 1 A customer files a Statement of Claim with FINRA DR, naming only

the firm as a respondent and containing the following allegations: “Claimant purchased the leveraged ETFs following a recommendation by her

brokers in the Jones Group that they would be a ‘good fit’ for her portfolio” “The firm marketed and sold these securities in a manner that did not disclose the

true risks of the product” “The sale of these products to Claimant was unsuitable based on her current

financial circumstances and goals” “The firm failed to ensure that its brokers made only suitable recommendations” “The Jones Group brokers are not named as respondents in this matter because

Claimant believes they made the recommendations at issue only in response to the firm’s pushing these products”

34


Examples and Explanations: Case Study 1 DETERMINATION: Under revised form U4 (Q14I(5)(A), and Reg. Notice 09-23), the firm must report

on the registered representatives U4 when it can determine that the rep was involved in the sales practice allegation. Here, the firm must make a good faith effort to determine who among the Jones Group made the alleged unsuitable recommendation. The additional allegations about the broker’s motivations (or lack thereof) does not alter the fact of his or her “involvement” in the sales practice claim (i.e. the solicited transaction);

While claims alleging specific failures to supervise would be reportable, even if the supervisor was not specifically named, here the allegations of a general failure on the part of the firm does not require reporting as to any particular individual.

35


Examples and Explanations: Case Study 2 A customer sends an email to her registered

representative stating: The client received a statement for a fixed annuity and was unhappy

that she received no interest since the annuity was purchased. The interest credited on the fixed annuity was not properly explained. The client wants out of the fixed annuity and the initial principal used

to purchase the annuity returned ($250,000) and wants the firm to reimburse her for any surrender charges incurred. The client has other mutual fund accounts with the broker.

36


Examples and Explanations: Case Study 2 DETERMINATION: The emailed complaint is not reportable on the representative’s U4 because the

complaint related to a fixed annuity (as opposed to a variable annuity) and does not amount to a “sales practice violation.”

The complaint is reportable on 4530(d) because the complaint is written and the client has other securities related accounts with the broker.

After further investigation, the firm decides to settle the customer’s complaint resulting in the firm returning the $250,000 principal and reimbursing the customer for the $16,000 surrender fee. This settlement is still not reportable on the U4 as it is not a sales practice violation, but it would be reportable under Rule 4530(a)(1)(G) as an insurance product was “financial related” and the threshold for settlements involving registered representatives ($15,000) was met.

37


Uniform Forms (U4/U5 and Explanation of Terms): www.finra.org/Industry/Compliance/Registration/CRD/FilingGuidance/

Forms U4 and U5 Interpretive Questions & Answers (as of 1/12/12) www.finra.org/web/groups/industry/@ip/@comp/@regis/documents/appsupportdocs/p119944.pdf

U4/U5 Revisions: Reg. Notice 09-23 www.finra.org/Industry/Regulation/Notices/2009/P118706

Electronic Filing Requirements for Uniform Forms: Reg. Notice 09-40 www.finra.org/Industry/Regulation/Notices/2009/P119432

38

Disclosure Reporting Key Resources

http://www.finra.org/Industry/Compliance/Registration/CRD/FilingGuidance/

http://www.finra.org/Industry/Compliance/Registration/CRD/FilingGuidance/

http://www.finra.org/web/groups/industry/@ip/@comp/@regis/documents/appsupportdocs/p119944.pdf


http://www.finra.org/Industry/Regulation/Notices/2009/P118706



U5 Obligations: Reg. Notice 10-39 www.finra.org/Industry/Regulation/Notices/2010/P122041 Rule 4530 Announcement: Reg. Notice 11-06

www.finra.org/Industry/Regulation/Notices/2011/P122889 Rule 4530 Announcement: Reg. Notice 11-32

www.finra.org/Industry/Regulation/Notices/2011/P123930 Rule 4530 Elimination of Duplicate Reporting: Reg. Notice

13-08 www.finra.org/Industry/Regulation/Notices/2013/P207601

39

Disclosure Reporting Key Resources (cont’d)






Consolidated Supervision Rules; Reg. Notice 14-10 (Effective: 12/1/14) www.finra.org/Industry/Regulation/Notices/2014/P465941

FINRA Rule 4530 – CRD Form U4 – Frequently Asked Questions www.finra.org/industry/compliance/registration/crd/usersupport/p223497

Compliance Guidance – Rule 4530 Events – Customer Complaint Filings www.finra.org/industry/compliance/regulatoryfilings/customercomplaints/

Rule 4530 Frequently Asked Questions www.finra.org/industry/faq-rule-4530-frequently-asked-questions

40

Disclosure Reporting Key Resources (cont’d)


http://www.finra.org/industry/compliance/registration/crd/usersupport/p223497


http://www.finra.org/industry/compliance/regulatoryfilings/customercomplaints/


http://www.finra.org/industry/faq-rule-4530-frequently-asked-questions


Regulatory Reporting Requirements Wednesday, May 25 10:00 a.m. – 11:00 a.m. Resources FINRA Notices

• FINRA Regulatory Notice 14-10, SEC Approves New Supervision Rules (Effective: 12/1/14) (March 2014) www.finra.org/sites/default/files/NoticeDocument/p465940.pdf

• FINRA Regulatory Notice 13-08, FINRA Amends Rule 4530 to Eliminate Duplicative Reporting and Provide the Option to File Required Documents Online Using a New Form (February 2013) www.finra.org/sites/default/files/NoticeDocument/p207600.pdf

• FINRA Regulatory Notice 11-32, FINRA Provides Additional Guidance Regarding Reporting Requirements Under Rule 4530 (July 2011) www.finra.org/sites/default/files/NoticeDocument/p123929.pdf

• FINRA Regulatory Notice 11-06, SEC Approves Consolidated FINRA Rule Governing Reporting Requirements (February 2011) www.finra.org/sites/default/files/NoticeDocument/p122888.pdf

• FINRA Regulatory Notice 10-39, Obligation to Provide Timely, Complete and Accurate Information on Form U5 (September 2010) www.finra.org/sites/default/files/NoticeDocument/p122040.pdf

• FINRA Regulatory Notice 09-40, SEC Approval and Effective Dates for New Consolidated FINRA Rules on Electronic Filing Requirements for Uniform Forms and Arbitration Disclosures (July 2009) www.finra.org/sites/default/files/NoticeDocument/p119431.pdf

• FINRA Regulatory Notice 09-23, SEC Approval of Proposed Changes to Forms U4 and U5 and FINRA Rule 8312 (FINRA BrokerCheck Disclosure) (May 2009) www.finra.org/sites/default/files/NoticeDocument/p118705.pdf

http://www.finra.org/sites/default/files/NoticeDocument/p465940.pdf








Other Resources:

• Uniform Forms (U4/U5 and Explanation of Terms) www.finra.org/sites/default/files/AppSupportDoc/p468051.pdf

• Forms U4 and U5 Interpretive Questions & Answers (as of 1/12/12)

www.finra.org/web/groups/industry/@ip/@comp/@regis/documents/appsupportdocs/p119944.pdf

• FINRA Rule 4530 – CRD Form U4 – Frequently Asked Questions www.finra.org/industry/compliance/registration/crd/usersupport/p223497

• Rule 4530 Frequently Asked Questions www.finra.org/industry/faq-rule-4530-frequently-asked-questions

• Compliance Guidance - Rule 4530 Events - Customer Complaint Filings www.finra.org/industry/compliance/regulatoryfilings/customercomplaints/

https://www.finra.org/sites/default/files/AppSupportDoc/p468051.pdf




http://www.finra.org/industry/faq-rule-4530-frequently-asked-questions
