Comments on Notice to Members 06-31

My comment relates to the processing of form U4 and U5 in the event of a pandemic. It must be taken into account that firms may of necessity, due to quarantine restrictions, authorize associates to process these forms from home rather than an alternate work site. It may also be possible that those for whom the forms are being processed may be restricted to their homes or to travel within limited geographic locations.

For processing of Form's U4 to transfer or initiate registration, firms should have an extended time period for submission of fingerprint cards to complete the process, if necessary. Conditional registration status should be extended beyond the current 30 day period. Conditional status should be available to individuals previously registered even if the current 30 day time period has passed.

Firms should also be excused from mailing copies of form U5 to a terminated individual if the individual(s) processing form U5 (possibly from a home PC) are subject to quarantine and cannot obtain postage or may not be permitted to leave their residence.

Notice for request for extensions on filing fingerprint cards or mailing of U5s could be sent to the NASD via email.