Revolutionizing the Digital Experience: Form U4 and FINRA Gateway
For the last couple of years, FINRA has been working to revolutionize the digital experience of firms, particularly when it comes to registration and disclosure. Now many of these changes have come to life through the new FINRA Gateway and an enhanced Form U4 filing experience.
On this episode, we talk to Credentialing, Registration, Education and Disclosure’s Noah Egorin and Technology’s Claudia Holanda to hear about recent changes and what firms and registered reps alike can expect going forward as FINRA continues to iterate and improve the digital experience.
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00:00 - 00:25
Kaitlyn Kiernan: For the past couple of years, FINRA has been working to revolutionize the digital experience of firms, particularly when it comes to registration and disclosure. Now, many of these changes have come to light through the new FINRA Gateway and a new Form U4 filing experience. On this episode, we hear more about recent changes and what firms and registered reps alike can expect going forward as FINRA continues to iterate and improve.
00:25 – 00:35
00:35 - 00:53
Kaitlyn Kiernan: Welcome to FINRA Unscripted, I'm your host, Kaitlyn Kiernan. We're welcoming two new guests to the show today. We have Noah Egorin from our Credentialing, Registration, Education and Disclosure Team, or CRED. And we have Claudia Holanda from FINRA Technology. Noah and Claudia, thanks for joining us.
00:54 - 00:54
Claudia Holanda: Thanks for having us.
00:55 - 01:04
Kaitlyn Kiernan: As first-time guests, before we get started today, can you tell us a little bit about yourselves and what you do at FINRA? Claudia, maybe you can kick us off?
01:05 - 01:43
Claudia Holanda: I joined for less than a year ago after spending some 20 years in various sectors of technology, building digital experiences and tools, with the five previous years being within the financial industry. And my role here as Director of Product Management, Enterprise Technology team, is really to work with our member firms and internal business units to drive innovation, set the vision and the strategy for FINRA's Digital Experience Transformation. Most listeners will know the digital transformation more as the FINRA Gateway.
01:43 - 01:44
Kaitlyn Kiernan: Noah, how about you?
01:45 - 03:23
Noah Egorin: I have been with FINRA and actually NASD to start for now over 17 years. I came to FINRA after starting my career at Microsoft and then a startup product development consulting company. In my first 15 years at FINRA, I worked in and then led a unit building tools and services to assist broker dealers with compliance. People may know the FINRA Report Center as one of the areas that I helped bring to life. Specifically, we were looking at opportunities to provide individuals with tools where industry vendors were not focused or where we had unique information and unique opportunities.
More recently, I joined the CRED team to help transform how FINRA's registration program operates and specifically a lot of focus on Web CRD. CRED is short for Credentialing, Registration, Education and Disclosure. It's the unit that many people probably formerly knew is RAD, or Registration and Disclosure. However, as our unit has evolved to include testing and continuing education programs, we felt it was important to rename the unit to really better represent the breadth of responsibility.
CRED's role is to ensure that the organizations and individuals in the industry are properly registered and qualified. Where the rubber really meets the road is that we do the work to run Web CRD, the Central Registration Depository program, FINRA's testing and continuing education programs, the public disclosure program, BrokerCheck. Some of our work is done as FINRA’s regulatory responsibilities. Others we work with other regulators and in some cases, we are a vendor to partners in what we do. So, a lot of our work is done in collaboration with the SEC, with NAASA and individual state regulators.
03:24 - 04:00
Kaitlyn Kiernan: Thanks, Noah. The last time we had a podcast talking about CRED it was, like you said, Registration and Disclosure and it was with the group head, Derrick Linden. So, I encourage anyone to check out episode 29 if they want a little bit more of a back story on some of what we're going to be talking about today. Where I want to focus today is on some recent big changes we've made, as Claudia hinted at to FINRA Gateway, formerly, we had Firm Gateway. But I want to start with looking at Form U4. Noah, can you tell us a little bit about what Form U4 is and what purpose it serves?
04:00 - 05:15
Noah Egorin: The Form U4 is the Uniform Application for Securities Industry Registration or Transfer. Everybody in industry just calls it the Form U4. So, this is the filing that firms submit on behalf of individuals to request registration and continued registration with FINRA, the states and other participating exchanges. It is the primary source of information for a professional's record in CRD, or when we look at it from an investment advisor perspective, IARD, or the Investment Advisors Registration Depository.
The form contains information that identifies who the person is, their background, including some personal information like residential history, but work experiences, other business activities they may be involved in that are required to be reported by our rules. Similarly, the Form U4 also contains disclosures or self-reported disclosures that individuals in our industry are required to make in certain circumstances, primarily around customer complaints, arbitration claims, regulatory proceedings, bankruptcies, criminal history, civil litigation and similar type of events with the idea that this is the key information necessary for regulators to approve registrations and for some of that information being publicly disclosed to the investing public.
05:16 - 05:22
Kaitlyn Kiernan: And that's disclosed through FINRA's BrokerCheck or the SEC's IAPD website?
05:22 - 05:23
Noah Egorin: That's correct.
05:23 - 05:32
Kaitlyn Kiernan: And so FINRA recently rolled out a new Form U4 filing experience, which is in FINRA Gateway. Can you tell us what changed?
05:33 - 09:03
Noah Egorin: Sure, and I think, Kaitlyn, you hit the specific words that we need to be very careful about. It's the same U4, it's a new filing experience. So, we always want to highlight that. It's really important to understand that the questions haven't changed on the form. The requirements of the form haven't changed. The guidance around the form hasn't changed. Just the way that FINRA collects that information has changed.
So, the question is, why change if the form hasn't changed? Well, they're big drivers for why we're making these changes. For our first Phase I, web CRD was brought online in 1999. We took a paper-based form. We put it in a Web browser. And twenty-one years later, we've had tremendous advances in technology, best practices for providing data via the web that we want to take advantage of. Second, we saw big opportunities to improve the quality of information obtained. The changes to the filing experience were data driven. We looked at the number of times FINRA needed to intervene in a filing due to preventable filing mistakes in areas where changes to the experience should help avoid incorrect information being submitted.
This is especially important because, as we mentioned before, that information does go to the public through BrokerCheck and in the case of IAs through IAPD. So, it's really important that the information is accurate and we're protecting certain personal information that sometimes can make its way into Web CRD. So, the accuracy of that information is critical. Overall, these design changes were designed to reduce the number of times we have to send letters to a firm to correct something or to clarify something. So, we really want to reduce the amount of back and forth between FINRA staff and the firm, which really should save everybody time, effort and money.
Similarly, we've heard that the learning curve for CRD can be challenging. For individuals, and there are a number of them, who have CRD'd before it was Web CRD, they've told us that they really like Web CRD. But often newer people struggle. It takes them a long time. They make a lot of mistakes and they get frustrated using software and user interface and experiences that were developed in 1999. So, we really were focused on getting the data right the first time, spend less time providing data.
So, let's talk specifics because I just talked at the high level about what drove it. What filers of Form U4 are going to see is regrouping of questions. They're going to see DRPs that are in line, or the disclosure reporting page, when you have to answer yes to a disclosure question, will go in line. You're going to see better validations and completeness checks. So as a result, we can ensure we get better information the first-time coming in. The guidance that FINRA currently makes available on FINRA.org is being brought into the form contextually aware, so the right piece of guidance should be available to you with the ability to get all the guidance if you need it.
You'll also see improved redlining and just pure web functionality that a modern browser and modern technology allows us to do. So, there's lots of changes coming to the form. As we move forward, we're really hoping to evolve away from forms altogether. We'll need to produce a statutory form. That's the rule. But we want someone to change a residential address, not amended a U4. We want people to update their OBAs, or their Other Business Activities, and not amend a U4. We want people to be able to move a bunch of people from branch A to branch B, not fill out a bunch of U4s. While we need to create those statutory forms, we don't have to let you interact with the form to create them. So, our ability to separate data collection or the data collection experience from the form itself creates those opportunities, which we hope to bring forward in future releases and updates to the filing experience. A lot of the benefits from the work that Claudia's team has done in the FINRA Gateway.
09:04 - 09:11
Kaitlyn Kiernan: When will FINRA retire the classic CRD Form U4 functionality?
09:11 - 9:53
Noah Egorin: So, another important thing that we need to highlight, we are retiring just the classic U4 filing capability. We're not retiring all of CRD. The date that we will retire the classic U4 filing is April 5th. We've allowed a parallel period to give firms the ability to make that transition over time, adopt their procedures and really learn the system. But once again, we're only going to retire that one piece of functionality. You will see FINRA over time, remove other pieces of functionality from classic systems like Web CRD as they transition to the FINRA Gateway. But our intention, where possible, is to always create that parallel time period and give firms plenty of notice to make that transition.
9:54 - 9:59
Kaitlyn Kiernan: And have firms started using the new format in this parallel environment?
9:59 - 10:43
Noah Egorin: We have, we allow testing of the U4 for nearly six months in advance of making it available. So, firms that chance to start to learn and understand it, tell us things they liked and didn't like. When we launched this past fall, we saw a slow uptick. There are firms that are experimenting. Some firms have fully adopted. In one case, one firm has actually already referenced significant cost savings from making the jump to the new system. We know that firms have procedures and processes and have really built routine to ensure that they operationalize this and will need time to convert. But we're seeing that uptick in usage and really do encourage firms to start trying it, using it and making that change in advance of April when it becomes a hard deadline.
10:44 - 10:50
Kaitlyn Kiernan: And you mentioned one firm mentioning cost savings so far. What other feedback have you heard so far?
10:50 - 12:10
Noah Egorin: We've received a tremendous amount of feedback from those individuals who have started adopting both the FINRA Gateway and specifically the U4 filing experience. The feedback that we've received has been positive in a number of areas. Firms like the in-line DRPs, they like the visual design. They've described, as we mentioned before, the hundreds of hours saved by switching to the new Allow Rep edits using FinPro. We've also seen areas of feedback where the industry is saying "you can change things; we can make things better." Specifically, as it relates to the Allow Rep edits, we've heard there's been some confusion about how a register rep sends the form back to the firm. So, we're going to rebuild that and that's actually going to change on the 23rd of January.
We've received feedback that some people have challenges when they try to navigate our form using the keyboard. We're addressing that based on the feedback we've gotten. We've also been told that we're killing a small number of forests as people try to print the entire U4. So, we're introducing a feature to let people print the U4 by section. The feedback that we get is important to get both areas where people think we can do better and where they may be more critical of what we've built, but also things they like so we do more of it. And we encourage that feedback to come in as many ways and as frequently as firms feel they need to.
12:11 - 12:17
Kaitlyn Kiernan: So, we've talked a lot about the Form U4, but are any of the other forms available in the new format too?
12:17 - 13:12
Noah Egorin: So right now, we are just focused on the Form U4. It is by far the most heavily used form in CRD, it is the reason we started with it. Similarly, all of the investment we are making in the U4 benefits subsequent forms as we introduce them down the road. The next form that we will introduce will be the Form U5. Testing of that form will begin pretty soon after that April 5th transition date. And we're currently targeting a May date to make that available. Once again, that would become available in parallel to the classic filing experience with a transition period to then retire the old functionality. But that'll happen over a period of time. And then you'll see the other forms come online behind that. You'll see us start to focus on Form BR, Form BD and some of the SEC forms that need to come over to a new platform. But they all benefit from the work being done on the U4 and you'll see the pace pick up because of that, now that the underlying technology has been built.
13:12 - 13:24
Kaitlyn Kiernan: And it seems like a lot of the changes lately, the transition from Firm Gateway to FINRA Gateway, this change with Form U4 first, a lot of the changes are being done incrementally. Why It is that?
13:24 - 14:20
Noah Egorin: A lot of the incremental change is driven by our mentality as an enterprise, not just from the CRD team. But once again, if we built in smaller chunks, we have time to fix things. We have time to introduce items to firms in smaller pieces so they can provide feedback. We have the ability to help firms adjust to those transitions as opposed to just dropping 21 years' worth of functionality. And then when you start adding in the rest of FINRA's applications, the Report Center, FOCUS, the form filing applications, it becomes a very big change when you're not just talking about building a new piece of software that works exactly the same. Firms have built procedures, operations, repeatable processes, testable operations based on the software we've built. And we need to give people a chance to adopt, change and make sure we're adding value along that path. So, if we do make a decision that doesn't create value for the firms, creates a burden, we have the ability to quickly address that.
14:21 - 15:05
Claudia Holanda: One thing that I would say about that is that as we're building with our users and we are getting feedback from them, we stop, and we might pivot. They might not be the right time, or we might not be going in the right direction that we thought we were to provide the benefits and the time savings and reducing compliance risk that we were aiming. So, we need that time to do it correctly. We need that time to adjust. We need that time to give our users time to adjust as well. It's like Noah said, it's too much of a change to just say, "hey, we're shutting everything down in one day and now everybody has to just deal with it and come over to the new site." Nobody likes that abrupt type of a change.
15:06 - 15:13
Kaitlyn Kiernan: So, Noah you mentioned April 5th is the date for the Form U4, but when will FINRA shut down class CRD?
15:14 – 16:52
Noah Egorin: So, we haven't yet announced a date and it will take time. We don't want to just put a hard stake in the ground and say "this is the date" because we are being driven by the data that we receive and the feedback we receive. If we see adoption not occurring as quickly as we need to, we can move that time frame. If we see feedback that says you got it wrong or it really needs more to be able to really replace what we do because of this very good reason, we can do that. And similarly, what we found is if we set a date and something happens, the communication process for us to help the industry understand, "hey, we had to move that date," takes effort and time and people may miss it. So, we want to communicate in smaller chunks.
We don't want to say on a specific date it's going to happen because we want to be agile, we want to be flexible and want to be receptive to the industry's feedback, concerns and communication. And we've already done that once. We originally had a date for the U4, the industry's impact to COVID, it was said, "wait a minute, this is a really bad time for us to make that change." And we had the ability to change our path.
To be honest, originally, we were going to just hard switch that U4 one day. They said, "you know what, parallel is better," and we were able to take that feedback and move forward. And in some cases, if our software has flaws or bugs, we have the ability to adjust that. And those are all important factors as we decide hard dates, soft dates or whatever other dates we need to pick. But we will try to communicate sufficiently. We will try to, as much as possible, communicate the parallel time frames. At this point, we're trying to give at least 90 days before we shut any feature down and try to keep parallel nature running when possible.
16:53 - 17:02
Kaitlyn Kiernan: We mentioned FINRA Gateway earlier, so the Form U4 changes are part of a larger transformation. How does it fit into the broader changes we're making?
17:02 - 18:18
Claudia Holanda: I mentioned before that I'm working with the Digital Experience Transformation, DXT for short. So, Noah mentioned before that most of the FINRA applications that our member firms interact with today use older technologies going back to the 90s. So, it makes it very difficult for us and costly to maintain these systems and provide the enhancements that many of our users are expecting. So back in 2018, FINRA embarked on this Digital Experience Transformation. So, it's a multi-year effort that leverages modern technologies with the goal to simplify digital interactions with FINRA systems and reduce compliance costs.
In 2019, the first rollout was the FINRA API, which enables the automation and time savings through machine-to-machine interactions between firms and third-party systems. And last year, FINRA Gateway. Those are the two major components of this transformation. And FINRA Gateway still has a couple of more years to go. That's the new interface meant to integrate and simplify our brokerage firms’ digital interactions with FINRA and building more effective compliance programs.
18:19 - 18:33
Kaitlyn Kiernan: And our listeners who want more background on the Digital Experience Transformation can check out Episode 36, which we recorded in June of 2019. What is the latest status on the new FINRA Gateway?
18:35 - 19:40
Claudia Holanda: Wow, there's a lot there, so we have two more years of work ahead of us, so I mentioned that it is a multi-year project. It's important to remember and reiterate what Noah mentioned, that this is an iterative approach to building FINRA Gateway. We are building in chunks and we are removing capability in chunks as well. So, we'll continue to build with our users and listening to them as to ease the transition to the new system.
So, today we believe we have built roughly 70 percent of all of the Firm Gateway features. Those are available in FINRA Gateway. We also retired new CRD, so all of the functionality from the new CRD system is already in FINRA Gateway, and that system was retired back in late August of last year. And the engagement has been so far so good. We have nearly 100 percent of all member BD firms having had at least one user log in to FINRA Gateway. So, I believe everybody knows about it. They're just getting used to and transitioning to using the different compliance tools in FINRA Gateway.
19:41 - 19:43
Kaitlyn Kiernan: Firm Gateway is still available for now?
19:44 - 20:36
Claudia Holanda: It is still available for now, but it's not going to be there forever. We are already redirecting Firm Gateway logins to FINRA Gateway, but our members have the ability to go back to Firm Gateway via quick links. And we are in the final stretch of transitioning all of the features from Firm Gateway. And our target is to retire Firm Gateway by the end of this summer. So, think about a July time frame. I'm not going to give an exact date, just like Noah mentioned. And we will provide ample notifications, at least 90 days’ notice for any specific day so firms have the time to complete any necessary training, provide feedback so we can adjust. So, it's coming. But don't panic. We'll provide all the necessary notices and training to help you transition.
20:37 - 20:39
Kaitlyn Kiernan: What kind of feedback have you received so far?
20:40 – 21:56
Claudia Holanda: First, let me just say that there are several ways for firms to provide feedback today. So, they can submit it via FINRA Gateway itself. They can participate in lightning feedback, invitations from FINRA Gateway, or signing up on FINRA.org through webinars, surveys or focus groups, or even sending us an email. And the amount of feedback that we receive, which, by the way, we read each and every one of them, and we work with our business counterparts and the technology to understand what our users are telling us. And this feedback ranges from the colors that we use or the layout of the new site, to even the ease or the difficulty of how to use some of the specific tools. A lot of them were about how the new reports flow today and how users have to leverage the templates and they can create and personalize their own reports. We heard from our users that it was difficult and required a lot of training. So, we adjusted. We made changes to the flow. We provided more training. So, the feedback ranges tremendously. But we welcome each and every one of those.
21:57 - 22:05
Kaitlyn Kiernan: Now, I want to talk a little bit about FinPro. What is FinPro? How is it different from or used in conjunction with FINRA Gateway?
22:05 - 24:34
Noah Egorin: So FinPro, or the Financial Professional Gateway, is really intended to be the registered rep and former register rep's home for interacting with FINRA and receiving information that they need. Before FinPro existed, FINRA had a handful of places on the website where a registered rep could do a handful of tasks, get a copy of their U4 information, take the regulatory elements CE, schedule an exam and such. We've brought them together in a single and secure location to be their home for their entire career. This account should follow the rep as they enter the industry, switch firms and even leave the industry. Its importance is growing and there's tremendous opportunities for FinPro to not just benefit the registered rep, but also the firms.
So FinPro is the opportunity to act as a utility for firms. Last fall we launched optional functionality that allows firms to work with their reps to confirm that their U4 information is up to date. Firms have processes and procedures, often an annual attestation program, or sometimes done multiple times during a year. This allows a rep to log in, look at the information on U4, click a button, say "yup, it's up to date". That information is provided back in the Dynamic Reporting Tool, or FINRA Gateway reports as it's now known, that Claudia talked about. We're similarly working on functionality that we hope to make available soon that will let FINRA notify reps that their regulatory CE obligation is due. So, work that today is done by the firm could be optionally allowed for FinPro to send that email. Once again, optional. Firms would control it. Firms would understand what has been sent and what hasn't been sent and be able to audit that. Those are important.
And we'll see more of that functionality continue to come forward as new features are built, including potentially using FinPro as an ability to sign a U4. Can't do that today based on our rules, but we hope to be able to bring capabilities like that forward, which should result in efficiencies for the industry, cost savings for everyone involved. As FinPro evolves, and as we have feedback from both the registered reps and the financial firms themselves, they'll really drive where we're taking the capabilities. Maybe it's providing contextually aware information to the registered rep throughout their career. You are switching firms, here's what you need to know, or here's what you need to do. You're about to exit the industry for more than two years, here's what you need to know about re-qualifying for exams if you want to come back in the industry. We've got lots of opportunities, but it really needs to be driven by the needs of the industry and those places we can have the biggest impacts.
24:36 - 24:45
Kaitlyn Kiernan: And where can firms learn more about FinPro, FINRA Gateway, Form U4 and all of these changes that are currently underway and upcoming?
24:45 - 25:08
Noah Egorin: So, I'll start with FinPro. If you go to FINRA.org/finpro, you'll see a tremendous number of resources targeted at firms and registered reps. You'll see templates that firms can use to help with FinPro communications. You'll see videos and short documents that can be distributed to help them adopt and change. Claudia, would you like to talk about the Gateway resources?
25:08 – 25:49
Claudia Holanda: So obviously FINRA.org is one of them. But users can also leverage the in-product tutorials that pop up from time to time after they log in that provides a summary of the new features available. And they can also launch these tutorials from within FINRA Gateway Knowledgebase. And also sign up for the webinars, that's another great opportunity to get live training about an upcoming feature. And firms can register for the webinars from the Events and Training page on FINRA.org. Also, on FINRA.org we have a section there specifically for FINRA Gateway, where we share our product roadmap with some of the upcoming features.
25:49 - 26:25
Noah Egorin: And I'll just add on for registration-specific functionality. FINRA.org has a tremendous number of resources: FAQs, training material, contacts for support, and it is a great place to help people both ramp up and answer questions they may have. Similarly, the FINRA.org subscription email list, and specifically the registration and testing information list, is a tremendous resource that we try to make sure we're communicating using those methods so that if they can't find something or they're not looking at FINRA.org, they're getting pushed information that's relevant, including when we intend to retire functionality and when new functionality becomes available.
26:26 - 26:42
Kaitlyn Kiernan: We'll link to all of those resources in our show notes, including a link to where you can sign up for that email subscription list. And we talked about the feedback you've received so far, but how can our listeners share their own feedback as they explore the new functionality?
26:43 - 27:29
Claudia Holanda: So, there's two ways. So, one is we have in FINRA Gateway on the top section, there's a button that says specifically "Send Feedback". So that comes directly to me and my team, and we read them, and we review them on a weekly basis. The other way is to send an email to [email protected] And again, those come to the product team and we review those. So please keep them coming! They're so critical. We really want to work with you guys. And don't be surprised if we reach back to clarify some of the questions that you have and even ask you to participate on a one-on-one zoom call so we can share some of our ideas with you and find out what do you think about.
27:30 - 27:59
Kaitlyn Kiernan: Perfect. Claudia, expect to get more emails coming up soon. Well, Claudia, Noah, thank you so much for joining us to provide an update on FINRA's new Form U4 filing experience and the latest regarding FINRA Gateway and FinPro. Listeners, if you don't already, you can subscribe to FINRA Unscripted on Apple Podcast, Spotify, or wherever you listen to your podcasts. And if you have ideas for future episodes, send them our way at [email protected] Until next time.
27:59 – 25:32
28:05 - 28:33
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28:33 – 28:39
Music Fades Out