FINRA Issues Guidance on Completing and E-signing Securities Registration Form

FINRA issued guidance to representatives of broker-dealers, investment advisers, and issuers on editing, reviewing, and electronically signing the Uniform Application for Securities Industry Registration or Transfer ("Form U4") in the FinPro Gateway.

FINRA instructions included:

• Firms can grant representatives access to work simultaneously on a pending Form U4 using the "Allow Rep Edits" feature. Representatives access the draft through a task list and can edit the form using the Data Entry View, which streamlines form edits.
• Firms' representatives should perform a final review in Form View, which aligns with the official format that will be submitted to regulators. Once the review is complete, the representative returns the form to the firm, because representatives cannot initiate or submit a filing directly to regulators.
• Firms can send a final, read-only version of Form U4 to collect an electronic signature from the representative, eliminating the need to print, sign, and scan documents outside the system. The signature field prepopulates with the representative's full name and the date, and the form is immediately returned to the firm upon submission.

In the guidance, FINRA also outlines several conditions and timeframes for the Form U4 process. Specifically, representatives can only edit a draft Form U4 under the condition that their firm explicitly enables the "Allow Rep Edits" feature. If edits are needed during the e-signature phase, only the firm has the authority to stop the signature process and re-enable editing. After the firm files Form U4, the data automatically updates in the FinPro Gateway within a time limit of 5 to 10 minutes. FINRA said that changes reported through BrokerCheck or IAPD will not occur unless the condition is met that the representative has at least one approved registration.

FINRA reminded registered individuals, they are subject to a continuing obligation to update required Form U4 information within a specified amount of time.