Skip to main content

Mapping of Disclosure Categories for FINRA Rule 4111

This category mapping is provided as a tool to assist member firms in understanding Rule 4111.  The terms used in this mapping are defined in Rule 4111, which controls their meaning.  This mapping guidance will be updated publicly as needed. 

The table below maps the disclosure events that are relevant for Rule 4111 (Restricted Firm Obligations) by category to the Uniform Registration Forms (i.e., Forms U4, U5, U6 and BD) and, where applicable, information released in BrokerCheck.  Specifically, it maps the following terms defined in Rule 4111:

  • Registered Person Adjudicated Events;
  • Registered Person Pending Events;
  • Registered Person Termination and Internal Review Events;
  • Member Firm Adjudicated Events; and
  • Member Firm Pending Events. 

These defined terms describe events that are reportable on the registered person’s or the member firm’s Uniform Registration Forms, as applicable.  The Member Firm Adjudicated Events category also describes some events that are based on customer arbitrations filed with FINRA’s dispute resolution forum, which FINRA has previously explained captures all BrokerCheck disclosures of arbitration awards against firms.   

Whether an adjudication, termination, or internal review event is counted for purposes of Rule 4111 also depends on whether the event was resolved during the Evaluation Period.  See Rule 4111(i)(10)(A), (C), (D); Rule 4111(i)(6) (definition of Evaluation Period).  To provide relevant guidance on this aspect of Rule 4111, the table below also maps to the fields in the Uniform Registration Forms Disclosure Reporting Pages (DRP) that indicate when the disclosure event reached a resolution. 

Specifically, in the table below: 

  • The mapping of the defined disclosure events to disclosure questions and fields in the Uniform Registration Forms assumes that the forms were completed fully, accurately, and timely. 
  • Where specific Uniform Registration Form disclosure questions and relevant DRP fields (i.e., the Form U4, U5 and BD columns) are listed for events described in Rule 4111, affirmative responses to the relevant disclosure questions act to identify the events described in Rule 4111, while the corresponding DRP fields provide necessary detail (e.g., relevant selections of structured data fields; event dates).
  • Where only relevant Disclosure Reporting Pages (DRP) fields are listed for events described in Rule 4111 (i.e., the Form U6 column), information in the DRP fields provide necessary detail and act to identify the events described in Rule 4111 (e.g., relevant selections of structured data fields; event dates).
  • Where the mapping is to BrokerCheck, the table explains how firms can access the relevant information on BrokerCheck.
  • Where “N/A” is listed, there are no applicable disclosure questions or DRP fields on the identified Uniform Registration Form.

For more information on Rule 4111, please refer to Regulatory Notice 21-34 and Information Notice 2/1/22.

Questions regarding this mapping guidance document should be directed to [email protected].

Mapping of Registered Person Adjudicated Events – Rule 4111(i)(4)(A)

Rule 4111(i)(4)(A)(i): “a final investment-related, consumer-initiated customer arbitration award or civil judgment against the registered person in which the registered person was a named party or was a ‘subject of’ the customer arbitration award or civil judgment”

Mapping of Rule 4111(i)(4)(A)(i) to Uniform Registration Forms:

Form U4

14I.(1)(b) or 14I.(4)(b)

Under Customer Complaint / Arbitration / Civil Litigation DRP, one of the following sets of disclosures:

  • Item 8 [Is the complaint, arbitration/CFTC reparation or civil litigation pending? “No”], Item 9 [Status: “Arbitration Award/Monetary Judgment (for claimants/plaintiffs)”] and Item 10 [Status date]

or

  • Item 13 [Is the arbitration/CFTC reparation pending?: “No”], Item 14 [Disposition: “Award to Customer” or “Judgment (other than monetary)”] and Item 15 [Disposition date]

or

  • Item 19 [Is the civil litigation pending?: “No”], Item 20 [Disposition: “Monetary Judgment to Customer” or “Judgment (other than monetary)”] and Item 21 [Disposition date]

Form U5

7E.1.(b) or 7E.4.(b)

Under Customer Complaint / Arbitration / Civil Litigation DRP, one of the following sets of disclosures:

  • Item 8 [Is the complaint, arbitration/CFTC reparation or civil litigation pending? “No”], Item 9 [Status: “Arbitration Award/Monetary Judgment (for claimants/plaintiffs”] and Item 10 [Status date]

or

  • Item 13 [Is the arbitration/CFTC reparation pending?: “No”], Item 14 [Disposition: “Award to Customer” or “Judgment (other than monetary)”] and Item 15 [Disposition date]

or

  • Item 19 [Is the civil litigation pending?: “No”], Item 20 [Disposition: “Monetary Judgment to Customer” or “Judgment (other than monetary)”] and Item 21 [Disposition date]

Form U6

Under SRO Arbitration DRP,

  • Item 9 [Is arbitration/reparation pending?: “No”], Item 10.A. [… how was arbitration/reparation resolved?: “Award” or “Stipulated Award”], and Item 10.B. [Resolution date]

 

4111(i)(4)(A)(ii):  “a final investment-related, consumer-initiated customer arbitration settlement, civil litigation settlement or a settlement prior to a customer arbitration or civil litigation for a dollar amount at or above $15,000 in which the registered person was a named party or was a ‘subject of’ the customer arbitration settlement, civil litigation settlement or a settlement prior to a customer arbitration or civil litigation”

Mapping of Rule 4111(i)(4)(A)(ii) to Uniform Registration Forms:

Form U4

14I.(1)(d), 14I.(2)(b), or 14I.(4)(a)

Under Customer Complaint / Arbitration / Civil Litigation DRP, one of the following sets of disclosures:

  • Item 9 [Status: Settled], Item 10 [Status Date] and Item 11.A. [Settlement / Award / Monetary Judgment amount ≥ $15,000]

or

  • Item 14 [Disposition: Settled], Item 15 [Disposition date] and Item 16.A. [Total amount ≥ $15,000]

or

  • Item 20 [Disposition: Settled], Item 21 [Disposition Date] and Item 22.A. [Total Amount ≥ $15,000]

Form U5

7E.1.(d), 7E.2.(b), or 7E.4.(a)

Under Customer Complaint / Arbitration / Civil Litigation DRP, one of the following sets of disclosures:

  • Item 9 [Status: Settled], Item 10 [Status Date], Item 11.A. [Settlement / Award / Monetary Judgment amount ≥ $15,000]

or

  • Item 14 [Status: Settled], Item 15 [Disposition date] and Item 16.A. [Total Amount ≥ $15,000]

or

  • Item 20 [Disposition: Settled], Item 21 [Disposition Date] and Item 22.A. [Total Amount ≥ $15,000]

Form U6

N/A

4111(i)(4)(A)(iii): “a final investment-related civil judicial matter that resulted in a finding, sanction or order”

Mapping of Rule 4111(i)(4)(A)(iii) to Uniform Registration Forms:

Form U4

14H.(1)(a) or 14H.(1)(b)

Under Civil Judicial DRP,

  • Item 8 [Current Status: “Final”], Item 11.B. [Resolution Date]

Form U5

N/A

 

Form U6

Under Civil Judicial DRP,

  • Item 8 [Current Status: “Final”], Item 11.B. [Resolution Date]

4111(i)(4)(A)(iv): “a final regulatory action that resulted in a finding, sanction or order, and was brought by the SEC or Commodity Futures Trading Commission (CFTC), other federal regulatory agency, a state regulatory agency, a foreign financial regulatory authority, or a self-regulatory organization”

Mapping of Rule 4111(i)(4)(A)(iv) to Uniform Registration Forms:

Form U4

14C., 14D. or 14E.

Under Regulatory Action DRP,

  • Item 12 [Does the order constitute a final order: “Yes”] and Item 11.B. [Resolution date]

Form U5

7D.

Under Regulatory Action DRP,

  • Item 8 [Status: “Final”] and Item 11.B. [Resolution date]

Form U6

Under Regulatory Action DRP,

  • Item 8 [Current Status: “Final”] and Item 11.B. [Resolution Date]

4111(i)(4)(A)(v): “a criminal matter in which the registered person was convicted of or pled guilty or nolo contendere (no contest) in a domestic, foreign, or military court to any felony or any reportable misdemeanor”

Mapping of Rule 4111(i)(4)(A)(v) to Uniform Registration Forms:

Form U4

14A.(1)(a) or 14B.(1)(a)

Under Criminal DRP,

Item 3.A. [Status: “Final”] and Item 3.B. [Status date]

Form U5

7C.1. or 7C.3

Under Criminal DRP,

Item 2.A [Event status: “Final”] and Item 2.B. [Event status date]

Form U6

Under Criminal DRP,

Item 3.A. [Event Status: “Final”] and Item 3.B. [Event Status Date]

 

Mapping of Registered Person Pending Events – Rule 4111(i)(4)(B)

4111(i)(4)(B)(i): “a pending investment-related civil judicial matter”

Mapping of Rule 4111(i)(4)(B)(i) to Uniform Registration Forms:

Form U4

14H.(2)

Under Civil Judicial DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

Form U5

N/A

 

 

Form U6

Under Civil Judicial DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

4111(i)(4)(B)(ii): “a pending investigation by a regulatory authority”

Mapping of Rule 4111(i)(4)(B)(ii) to Uniform Registration Forms:

Form U4

14G.(2)

Under Investigation DRP,

  • Item 4 [Is investigation pending: “Yes”]

Form U5

7A.

Under Investigation DRP,

  • Item 4 [Is investigation pending: “Yes”]

Form U6

Under Investigation DRP,

  • Item 4 [Is investigation pending: “Yes”]

4111(i)(4)(B)(iii): “a pending regulatory action that was brought by the SEC or CFTC, other federal regulatory agency, a state regulatory agency, a foreign financial regulatory authority, or a self- regulatory organization”

Mapping of Rule 4111(i)(4)(B)(iii) to Uniform Registration Forms:

Form U4

14G.(1)

Under Regulatory Action DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

Form U5

7A. or 7D.

Under Regulatory Action DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

Form U6

Under Regulatory Action DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

4111(i)(4)(B)(iv): “a pending criminal charge associated with any felony or any reportable misdemeanor”

Mapping of Rule 4111(i)(4)(B)(iv) to Uniform Registration Forms:

Form U4

14A.(1)(b) or 14B.(1)(b)

Under Criminal DRP,

  • Item 3.A. [Event Status: “Pending” or “On Appeal”]

Form U5

7C.2 or 7C.4

Under Criminal DRP,

  • Item 2.A. [Event Status: “Pending” or “On Appeal”]

Form U6

Under Criminal DRP,

  • Item 3.A. [Event Status: “Pending” or “On Appeal”]

 

Mapping of Registered Person Termination and Internal Review Events – Rule 4111(i)(4)(C)

4111(i)(4)(C)(i): “a termination in which the registered person voluntarily resigned, was discharged or was permitted to resign from a previous member after allegations”

Mapping of Rule 4111(i)(4)(C)(i) to Uniform Registration Forms:

Form U4

14J.(1), 14J.(2) or 14J.(3)

Under Termination DRP,

  • Item 2 [Termination type] and Item 2 [Termination Date]

Form U5

For Forms U5 filed by a previous member: 7F.1, 7F.2, or 7F.3

Under Termination DRP,

  • Item 2 [Termination Type] and Item 3 [Termination Date]

 

 

Form U6

N/A

 

4111(i)(4)(C)(ii): “a pending or closed internal review by a previous member”

Mapping of Rule 4111(i)(4)(C)(ii) to Uniform Registration Forms:

Form U4

N/A

 

Form U5

For Forms U5 filed by a previous member: 7B.

Under Internal Review DRP,

  • Item 4 and/or Item 5.A. [Date internal review concluded]

Form U6

N/A

 

 

Mapping of Member Firm Adjudicated Events – Rule 4111(i)(4)(D)

4111(i)(4)(D)(i): “a final investment-related, consumer-initiated customer arbitration award in which the member was a named party”

Mapping of Rule 4111(i)(4)(D)(i) to Uniform Registration Forms:

No applicable fields in any Uniform Registration Form;
Refer to the Awards section of the BrokerCheck Detailed Report

4111(i)(4)(D)(ii): “a final investment-related civil judicial matter that resulted in a finding, sanction or order”

Mapping of Rule 4111(i)(4)(D)(ii) to Uniform Registration Forms:

Form U6

Under Civil Judicial DRP,

  • Item 8 [Current Status: “Final”] and Item 12 [Resolution Date]

 

 

Form BD

11.H.(1)(a) or 11.H.(1)(b)

Under Civil Judicial Action DRP,

  • Part I A [Persons or Entities for whom DRP is being filed: “Applicant” or “Applicant and one or more control affiliate(s)”], Part II Item 8 [Current Status: “Final”] and Item 12 [Resolution Date]

4111(i)(4)(D)(iii):  “a final regulatory action that resulted in a finding, sanction or order, and was brought by the SEC or CFTC, other federal regulatory agency, a state regulatory agency, a foreign financial regulatory authority, or a self-regulatory organization”

Mapping of Rule 4111(i)(4)(D)(iii) to Uniform Registration Forms:

Form U6

Under Regulatory Action DRP,

  • Item 8 [Current Status: “Final”] and Item 12 [Resolution Date]

 

Form BD

11.C., 11.D., 11.E. or 11.F.

Under Regulatory Action DRP,

  • Part I A [Persons or Entities for whom DRP is being filed: “Applicant” or “Applicant and one or more control affiliate(s)”], Part II Item 8 [Current Status: “Final”] and Item 11 [Resolution Date]

4111(i)(4)(D)(iv): “a criminal matter in which the member was convicted of or pled guilty or nolo contendere (no contest) in a domestic, foreign, or military court to any felony or any reportable misdemeanor”

Mapping of Rule 4111(i)(4)(D)(iv) to Uniform Registration Forms:

Form U6

Under Criminal DRP,

  • Item 3.D. [Current Status: “Final”], 3.E. [Event Status Date], Item 4.A. [Disposition type: “convicted”, “pled guilty”, “no contest/nolo contendere”]

 

Form BD

11.A.(1) or 11.B.(1)

Under Criminal DRP,

  • Part I A [Persons or Entities for whom DRP is being filed: “Applicant” or “Applicant and one or more control affiliate(s)”], Part II Item 3.D. [Current Status: “Final”] and Item 3.E. [Event Status Date]

 

Mapping of Member Firm Pending Events – Rule 4111(i)(4)(E)

4111(i)(4)(E)(i): “a pending investment-related civil judicial matter”

Mapping of Rule 4111(i)(4)(E)(i) to Uniform Registration Forms:

Form U6

Under Civil Judicial DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

Form BD

11.H.(2)

Under Civil Judicial Action DRP,

  • Part I A [Persons or Entities for whom DRP is being filed: “Applicant” or “Applicant and one or more control affiliate(s)”], Part II Item 8 [Current Status: “Pending” or “On Appeal”]

4111(i)(4)(E)(ii): “a pending regulatory action that was brought by the SEC or CFTC, other federal regulatory agency, a state regulatory agency, a foreign financial regulatory authority, or a self-regulatory organization”

Mapping of Rule 4111(i)(4)(E)(ii) to Uniform Registration Forms:

Form U6

Under Regulatory Action DRP,

  • Item 8 [Current Status: “Pending” or “On Appeal”]

 

Form BD

11.G.

Under Regulatory Action DRP,

  • Part I A [Persons or Entities for whom DRP is being filed: “Applicant” or “Applicant and one or more control affiliate(s)”], and Part II Item 8 [Current Status: “Pending” or “On Appeal”]

4111(i)(4)(E)(iii): “a pending criminal charge associated with any felony or any reportable misdemeanor”

Mapping of Rule 4111(i)(4)(E)(iii) to Uniform Registration Forms:

Form U6

Under Criminal DRP,

  • Item 3.D. [Current Status: “Pending” or “On Appeal”]

 

Form BD

11.A.(2) or 11.B.(2)

Under Criminal DRP,

  • Part I A [Persons or Entities for whom DRP is being filed: “Applicant” or “Applicant and one or more control affiliate(s)”], Part II Item 3.D. [Current Status: “Pending” or “On Appeal”]

 

Mapping of Registered Persons Associated with Previously Expelled Firms

4111(i)(4)(F): “any Registered Person In-Scope who was registered for at least one year with a previously expelled firm and whose registration with the previously expelled firm terminated during the Evaluation Period.”

Mapping of Rule 4111(i)(4)(F) to Uniform Registration Forms:

No applicable fields in any Uniform Registration Form. FINRA will be publishing on its website a list of expelled firms. This list may be used in determining whether a Registered Person In-Scope is a Registered Person Associated with a Previously Expelled Firm. FINRA will provide notice when this additional resource is available.

Version 1: February 2022