CRD Frequently Asked Questions
Branch Office Registration
What is the Form BR?
The Form BR is the new Uniform Branch Office Registration form that enables firms to "register" or "notice file" branch offices electronically through Web CRD® with FINRA, the New York Stock Exchange, Inc. (NYSE) and other participating jurisdictions. Information about "registering" or "notice filing" branch offices using the Form BR is available at:
For general questions, call FINRA's Gateway Call Center - (301) 869-6699.
Which jurisdictions are participating in the Branch Office Registration and Branch Office Notice Filing Programs?
See the NASAA Web site at www.nasaa.org for information on which jurisdictions are participating in the Branch Office Registration Program.
What is the difference between “registering” a branch office and “notice filing” a branch office?
Regulators participating in the Branch Office Registration Program require branch offices to be either “registered” or “notice filed.” Although these terms may be used interchangeably by self-regulatory organizations (SROs) and/or states, “registering” typically refers to a process that requires an approval by the SRO or state before a branch may begin doing business, whereas “notice filing” typically refers to a process by which firms notify an SRO or state of the existence of a branch office, but an approval is not required. Regulators that require “notice filing” of a branch office will mark the branch as “Open” in the Web CRD system upon receipt.
Will fees for opening a branch office be deducted from my Web CRD account?
FINRA and state fees for opening a branch office will be deducted from your firm’s Web CRD account. For a list of state fees, please refer to the SRO/State Fee schedule. NYSE registration fees for opening a branch office will not be deducted from your Web CRD account. NYSE will charge these fees directly to firms.
(Effective July 3, 2006, FINRA will charge a $20 branch processing fee - see NASD NTM 06-25.)
Section 2 (Registration/Notice Filing/Type of Office) asks firms to indicate if the branch office is an OSJ or a non-OSJ. When the branch is a non-OSJ, the firm must provide the CRD Branch Number, or Firm Billing Code, for the OSJ branch office that has supervisory responsibility for the (non-OSJ) branch office and the CRD Number for the supervisor of that OSJ. However, some OSJs are responsible for multiple branches and have designated different supervisors to be responsible for those branches. Should I report the supervisor in charge of the OSJ or the supervisor within that OSJ that has been designated responsibility for the non-OSJ branch?
Regulators are interested in knowing the identity of the individual who has supervisory responsibilities for the non-OSJ branch office. Firms should report the CRD Number for the individual who is designated by the OSJ to supervise the non-OSJ branch. This individual must also be listed as a supervisor for the OSJ Branch. For some firms, the supervisor of the OSJ will also be the supervisor designated to be in charge of the non-OSJ branch. Note: The Form BR instructions state that firms should identify the supervisor of the OSJ in this field. Accordingly, firms may report the name of the supervisor of the OSJ in this field; however, such firms should be prepared to identify, for purposes of a regulatory request, the person with supervisory responsibility for the non-OSJ.
If my firm has only a main office (and no other locations), must I register the main office as a branch office?
To determine whether a firm needs to register its main office via the Form BR under the new uniform definition of "Branch Office" (which takes effect on July 3, 2006), firms should review the new uniform branch office definition in NASD Rule 3010(g)(2) and Notices to Members 05-67 and 06-12. Firms (and their legal counsel) are responsible for determining whether a main office meets the current (or new) definition of “Branch Office” and therefore must be registered/notice filed on the Form BR.
If the Chief Compliance Officer (CCO) works at a location where there are no registered representatives, is the location required to be registered as a branch?
It depends on the function/activities occurring at the location. In some firms, Compliance serves a control function, similar to Internal Audit, and is not part of the supervisory structure. If this is the case, then the location from which the CCO works would not have to be a registered branch, presuming there are no other activities at the location that would require the location to be registered as a branch. In some firms, however, Compliance may serve a supervisory role. If the CCO is supervising the activities of associated persons at other non-branch locations, then the CCO's location would have to be registered as a branch office. Further, if the CCO is supervising the activities of associated persons at other branch locations, then the CCO's location would be designated an OSJ.
Section 2 (Registration/Notice Filing/Type of Office) asks the firm to report the name and/or CRD # of each supervisor(s)/person(s)-in-charge. Must the supervisor(s) or person(s)-in-charge reported be physically located at the branch office being registered (or notice filed)?
Yes. The supervisor(s) reported for every OSJ branch office and the person(s)-in-charge reported for every non-OSJ branch office must be located on-site at the branch office being registered (or notice filed). Do not report the name(s) of off-site supervisors in response to this question on the Form BR.
Section 2 (Registration/Notice Filing/Type of Office) asks the firm to report the name and/or CRD # of each supervisor(s)/person(s)-in-charge. Must the firm report a supervisor or person-in-charge for every branch office?
Yes. A firm must report a supervisor(s) for every OSJ branch office and a person(s)-in-charge for every non-OSJ branch office. Refer to the "Explanation of Terms" section of the Form BR for the definitions of these terms. FINRA members are directed to NASD Rule 3010(a)(4) which requires a firm to designate one or more appropriately registered principals in each OSJ, including the main office, and one or more appropriately registered representatives or principals in each non-OSJ branch office with authority to carry out the supervisory responsibilities assigned to that office by the member. A firm may designate a registered individual as the person-in-charge in a non-OSJ branch office with limited supervisory responsibilities that do not trigger registration as a principal.
How should a firm complete the last question in Section 2 (Registration/Notice Filing/Type of Office) that asks the firm to report the name and/or CRD # of each supervisor(s)/person(s)-in-charge for a single-person branch office and a single-person, sole proprietorship broker-dealer?
A firm registering a single-person branch office should indicate the person in that branch office as the "person-in-charge" for the sole purpose of answering this question on the Form BR. Although "person-in-charge" is defined in the "Explanation of Terms" section of the Form BR as an on-site person with supervisory responsibilities, NASD rules do not permit a registered person to supervise himself or herself, with the exception of single-person, sole proprietorship broker-dealers. Therefore, FINRA will consider the registered individual in a single-person branch office designated as a "person-in-charge" to be acting as a contact person for purposes of the Form BR.
If the branch office being registered is a single-person, sole proprietorship broker-dealer, indicate the registered person in that branch office as a "supervisor," because such person must be a registered principal.
If none of the individuals at a non-OSJ branch office are registered principals (and they are supervised by one or more individuals located at an OSJ or other registered branch office), is the firm required to report on the Form BR a principal located at the non-OSJ branch office?
No. As an initial matter, a member must designate a branch office as a non-OSJ or an OSJ branch office, depending on whether the branch any office that conducts any of the functions set forth in NASD Rule 3010(g)(1). If a branch office is not an OSJ, under NASD Rule 3010(a)(4), a member need only designate one or more appropriately registered representatives located at the branch with authority to carry out the supervisory responsibilities assigned to that office. In such situations, the firm should report such individual(s) as the person(s)-in-charge at that branch in Section 2 of the Form BR. As defined in Form BR, a person-in-charge is not required to be a principal.
What information is being sought in Section 4 (Branch Office Arrangements)?
Section 4 (Branch Office Arrangements) is seeking information about office sharing arrangements, except for sales agreements or insurance agency agreements between the main office and registered persons working at the branch. This information was previously reported on Schedule E of the Form BD. Among other things, these questions elicit information about: (1) contractual arrangements between an independent contractor branch office and the firm's main office; (2) expense-sharing relationships between a parent company and the branch office; and (3) space sharing arrangements between a branch office and a bank or other types of non-investment financial entities.
Should a firm complete Section 5 (Associated Individuals) of the Form BR in the case of a single-person branch office or in the case of a single-person, sole proprietorship broker-dealer?
No, in the case of a single-person branch office, the firm will have reported that individual as the "person-in-charge" in Section 2 (Registration/Notice Filing/Type of Office). In the case of a single-person, sole proprietorship broker-dealer; the firm will have reported that individual as the "supervisor" in Section 2 (Registration/Notice Filing/Type of Office). Therefore, in these cases, the firm should not report this individual again in Section 5 (Associated Individuals) of the Form BR.
Does Form BR Section 5 (Associated Individuals) require firms to list the non-registered individuals (who maintain a CRD record via the NRF, non-registered fingerprint individual, functionality) who are located at a branch office?
No. Report only registered individuals in Form BR Section 5.
Section 7 (Branch Closing) requires the firm to report the "location of books and records." What books and records must the firm maintain in the event of a branch closing?
Section 7 (Branch Closing) does not mandate which books and records a firm must maintain in the event of a branch closing. It only requires that the firm report the address where the books and records of the closed branch will be kept. A firm's books and records requirements may be found in rules 17a-3 and 17a-4 under the Securities Exchange Act of 1934.
When a Section 7 (Closing/Withdrawal) is filed, what happens to the individuals associated with that location?
If the branch office being closed is the sole Office of Employment Address for an individual, the firm will need to file a Form U4 amendment to update the individual's Office of Employment Address and associate him/her with another registered Office of Employment Address location before the Form BR branch closing or withdrawal can be submitted.
If an individual is associated with more than one registered Office of Employment Address location, there is no need to update the individual's Office of Employment Address on the Form U4 when submitting the Form BR closing or withdrawal, because the association between the individual and the branch office will be closed when the Form BR closing/withdrawal is submitted. The individual’s record will be updated, and the end date used on the individual’s record will be the date the Form BR Closing/Withdrawal was filed.
Can a firm view a Form BR filed by another firm?
No. The only users who are able to view the actual Form BR filing that affected the individuals’ record are users associated with the firm that submitted the Form BR filing. However, all firms will be able to see the Form BR "Form Type" listed in the individual’s filing history.
What changes have been made to the Form U4 to support the Form BR?
Section 1 (General Information) and Section 6 (Registration Requests with Affiliated Firms) now elicit whether a person has an independent contractor relationship with the firm.
The Office of Employment Address in Section 1 (General Information) and Section 6 (Registration Requests with Affiliated Firms) was modified to enable selection of a registered or non-registered location; to indicate whether the individual is located at or supervised from the designated location; and to enable the designation of multiple Office of Employment Addresses
Can a firm assign a non-registered individual to a branch office?
No. Firms may only assign/link a registered individual to a branch office via the Form U4
With the implementation of the Branch Office Registration Program, all FINRA registered individuals are required to be associated with/linked to a minimum of one registered Office of Employment Address as reported in Section 1 (General Information) of the Form U4. What is a registered Office of Employment Address for purposes of the Branch Office Registration Program?
A registered Office of Employment Address can be:
NOTE: A firm may need to register its main office as a branch office if it meets the definition of branch office set forth in Rule 3010(g) (2), NYSE Rule 342, or the rule(s) adopted by other SROs or participating jurisdictions. See Q&A No. 8. (Rule 3010 and main office require to be registered)
Can a firm specify a Supervisor/Person-In-Charge for a branch office on a Form U4?
No. When a firm associates an individual with a branch office on the Form U4, the individual is considered an "Associated Person" of the branch. In order to designate that individual as a Supervisor/Person-in-Charge, the firm must file a Form BR amendment.
If an individual is currently listed as a Supervisor/Person-In-Charge for a branch, what happens to the individual’s record when a Form BR amendment is filed to remove that individual from the role of Supervisor/Person-In-Charge for that branch?
When a Supervisor/ Person-In-Charge is removed on a Form BR amendment filing, that individual will remain associated with the branch in a non-Supervisor/ Person-In-Charge role. In order to completely remove this individual from being associated with the branch, the firm must file a U4 amendment to provide an end date to the individual's Office of Employment Address location.
When filing a Form U4, I received the following completeness check: "A gap of more than one day between Office of Employment Address with the same firm is not allowed." How can this be corrected?
The purpose of this completeness check is to prevent the firm from submitting a Form U4 where: 1) all of the Offices of Employment Address associations are being closed and the firm has not added a new Office of Employment Address for the individual; or 2) the firm is ending the association with all Offices of Employment Address and the start date for the new Office of Employment is after the end date provided for the Office of Employment Address association that is being closed. After receiving this error, the firm must review Item 1 (General Information) on the Form U4 to make sure the individual has at least one Office of Employment Address association that does not have an end date provided, and make sure the individual is not associated with an Office of Employment Address for more than one day.
When a firm files a Form BR amendment to update the address of the branch office, should the firm file U4 amendments for all of the individuals associated with that location?
No. Firms do not need to file U4 amendments for the individuals associated with that location to reflect the branch address change. The Form BR information is linked to the Form U4 so the address change made on the Form BR will also update the records of the individuals associated with that branch office.
If a firm opens a new branch and adds a new registered person who will be a supervisor or person-in-charge of the new branch, which should the firm file first – the Form BR or Form U4?
Firms should follow a 3-step process: (1) File an Initial Form U4 to register the individual, and assign the individual to the firm’s main office (i.e., BDMAIN or IAMAIN) as a “placeholder” Office of Employment Address; (2) File the Initial Form BR to register the location as a branch and select the individual to be a Supervisor/Person-In-Charge of the branch (the Form BR filing will automatically create an Office of Employment Address for the branch on the Individual’s record); and (3) File an amended Form U4 to close out the assignment to the main office.
Where can a firm find information on which of its registered persons are not associated with or linked to a registered location?
Firms are able to request a free ad hoc report that will identify the individuals, to date, who remain unlinked. The report, delivered in Excel format via email, includes the individual's name, CRD number, billing code (if provided) and all open non-registered office of employment addresses. The report does not include individuals for whom the firm has completed the linking. To request this report, send an email to Web CRD. Please include your firm CRD #, your contact information and specify that you are requesting the "Unlinked Registered Representatives Report."
How did FINRA determine what branch offices to convert during the transition period?
FINRA obtained data files from the NYSE and the following states: Connecticut, Florida, Maine, Nevada, Texas, Vermont and West Virginia. FINRA used this data, along with Schedule E branch data from Web CRD, to create the universe of converted branches.
What information was included in the branch office data conversion?
The conversion program used existing Web CRD data as well as the information provided by the NYSE and the participating jurisdictions to populate the following data items to the Web CRD system:
Were converted branches assigned a new CRD Branch #?
Yes. Each branch that was converted received a unique CRD Branch #. These numbers will begin in the 50,000 range.
How can my firm match the old Branch #s and the new CRD Branch #s?
Firms may request a free ad hoc report that will assist them in matching the new CRD Branch # with the old Schedule E Branch #. To request this report send an email to CRD. Please include your firm CRD #, contact information and specify that you are requesting the "Schedule E Branch CRD Number Matching Report."
During the conversion to Form BR of branches that were opened via Schedule E, which date did FINRA use as the “effective date” for the Supervisors of those converted branches?
For purposes of the conversion, FINRA used the individuals' date of hire with the firm as the "effective date" (i.e., the date that they became supervisors at that branch) as shown on Form U4.
Can the non-registered locations that were created as part of conversion be removed from the individual's record?
No. The converted locations cannot be removed. The firm can file a U4 amendment to close the individual's association with the non-registered location by putting in an end date and creating a new office of employment association if needed.
The NYSE has provided the following information. Please direct any additional NYSE specific questions to Joseph Sheirer at the NYSE at (212) 656-5917.
Are firms able to submit branch office applications via the NYSE's EFP Branch Office System?
All applications must be submitted via the Web CRD system using the Form BR.
How is the NYSE Branch Office Code selected?
The NYSE Branch Code is a mandatory designation selected by the firm, unique to each of its locations, to identify a branch office. This code can be up to 15 alpha/numeric characters. If an office is closed, the NYSE Branch Code for that office cannot be re-used for a period of three years unless the branch is re-opening at the exact same address.
NYSE Question #5 asks for the CRD number of the on-site Supervisor/Person-in-Charge who is responsible for the supervision at this location. Must the individual be on-site?
For regular branch offices, this is the person on-site who has overall supervisory responsibility for that branch office and has the proper supervisory qualifications. For small branch offices, this is the person off-site who has supervisory responsibility and the proper supervisory qualifications unless the on-site person in charge of that office has the proper qualifications to supervise the activity being conducted.
Will the NYSE continue to issue approval letters and certificates upon approval of an initial application?
Yes. The approval letters can be viewed and printed via the "Branch Status Queue".
Why must the NYSE certificate question be completed when submitting an amendment?
This question should only appear on initial filings. Firms will not receive new certificates based upon amendments. This is a requested enhancement for the next Form change.
Will the NYSE space sharing section of the application now permit multiple space sharing arrangements?