What is Form U4 for?
FINRA, other self-regulatory organizations and the states use Form U4 to collect employment history, disciplinary and other information about individuals in order to register them. FINRA-member broker-dealers must file it on behalf of proposed associated persons under FINRA Rule 1013. Investment adviser firms file it for each investment adviser representative they register with the states. Registered individuals have a continuing obligation to keep the information on their Form U4 current by amendment.
When is Form U5 filed?
A Form U5 must be filed when an individual leaves a firm for any reason, within thirty days of the individual's employment end date, and generally must be filed electronically. The firm, not the departing advisor, files it, and it must give the individual a copy within thirty days.
For a full termination the firm picks one reason: Voluntary, Deceased, Permitted to Resign, Discharged or Other. The last three need a written explanation. A partial termination, which drops some registrations while the person stays at the firm, gives no reason. The firm has a continuing obligation to amend and update the form's disclosure questions until a reported matter reaches final disposition.
Where does the information go?
Both forms are filed into FINRA's Central Registration Depository, which holds registration records including qualification, employment and disclosure histories. Each person in it has a CRD number. FINRA's BrokerCheck and the SEC's IAPD draw on that record.
Where it shows up in our data
A move in our data is, in effect, the pair of filings: a registration ending at one firm and a registration beginning at another, as the SEC's IAPD records show for investment adviser representatives (IARs). Flight Window shows how long advisors stayed before moving, and Methodology explains what counts as a move.
Sources
- Rule textForm U4 FINRA
- Rule textForm U5 FINRA
- Rule textForm U5 (form text) FINRA
- Public recordBrokerCheck FINRA
- Continuum dataMarket Intelligence methodology Continuum
- ReferenceInvestment Adviser Guide NASAA
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