FINRA Streamlines Recordkeeping for Registration Form Filings

FINRA informed member firms that those using its E-Signature system may now rely on the Central Registration Depository ("CRD") to meet record retention requirements for registration form filings.

In a Regulatory Notice, FINRA explained that Rule 1010 ("Electronic Filing Requirements for Uniform Forms") requires firms to base each Form U-4 ("Uniform Application for Securities Industry Registration or Transfer") filing on a signed copy from the individual being registered and to retain it under Exchange Act Rule 17a-4 ("Records to be preserved by certain exchange members, brokers and dealers"). FINRA said it expanded no-action relief allowing firms using its E-Signature system to meet these recordkeeping obligations via CRD, eliminating the need to separately store signed Form U-4s. FINRA noted that the change streamlines compliance while maintaining adherence to existing rules.

FINRA outlined procedures for using E-Signature, including verifying that the individual has a Financial Professional Gateway account, sending the Form U4 for review and electronic signature, and completing the firm’s signature block before submitting the filing to CRD. FINRA noted that participation in the E-Signature program is voluntary, but said it will continue exploring enhancements to its systems aimed at supporting member compliance and reducing unnecessary administrative burdens.

FINRA stated that the recordkeeping changes are effective immediately on October 10, 2025.