Registration Filing in FINRA Gateway
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Form U5, Disclosure Letters and Reports
Several features in the Classic CRD system are scheduled to partially or completely retire on August 21, 2021. More information about these system changes is provided below:
Individual Disclosure Letters
Enhanced individual disclosure letters will become available in FINRA Gateway Requests May 1. With this launch, firms will be able to respond to letters and upload relevant documents within the system. Additionally, more information will be included in the summary disclosure letter display, including a response deadline. The ability to view disclosure letters in Classic CRD will be retired no earlier than August 21.
FINRA encourages firms to begin using this feature and provide feedback to FINRA while disclosure letters are accessible in both Classic CRD and FINRA Gateway for the next several months. Adjustments to work processes may be required to prepare for the transition from Classic CRD to FINRA Gateway. For example, firms that currently send consolidated responses to FINRA that include information for multiple individuals should be mindful that FINRA Gateway will not support similar bulk upload procedures.
On May 17, firms can begin using the enhanced Form U5 filing experience in FINRA Gateway. Filers will be notified on the summary page if the individual has other relationships with the firm that may also require updating. If necessary, the enhanced filing experience will also automatically update the U5 filing type according to information provided in the draft. The ability to draft and submit Form U5 in Classic CRD will remain available through August 21, 2021.
Classic CRD Reports will be updated in the coming weeks to include links to several corresponding report templates in FINRA Gateway. FINRA encourages firms to test out these templates and send feedback through the FINRA Gateway system. On August 21, reports in Classic CRD with a link to a FINRA Gateway template will be retired and no longer available to run or view. All other reports in Classic CRD will remain available until a retirement date is set and announced.
FINRA will continue to publish updates in this space as information becomes available about the transition of registration filing activities from Classic CRD to FINRA Gateway. Additional information about managing registration compliance work in both systems can be found on the CRD is Moving to FINRA Gateway page, and recordings from recent webinars about these system features will be made available shortly on the Registration System Changes Webinar Series page.
Form U4, Form U5 and Disclosure Letters
Several significant registration filing milestones will occur over the coming weeks:
The ability to file Form U4 in Classic CRD will retire April 5. All other system functionality will remain available, and firms are not required to recreate Form U4 filings that were already submitted. Form U4 drafts in Classic CRD must be submitted on or before April 4; otherwise, they will be invalidated on April 5. Read-only versions of these invalidated drafts will be made available April 5 through May 15.
The Anonymous CRD Registered Representative site used to collaborate on Form U4 filings enabled with the Allow Rep Edits feature will also retire April 5, and Form U4 collaboration will be performed exclusively through FINRA Gateway and FinPro. For more information, see the Form U4 page and February 2021 Enhanced Form U4 Webinar Recording.
Starting May 17, firms can begin drafting and submitting Form U5 in FINRA Gateway. Form U5 filing functionality will be supported in Classic CRD for several months and will retire no earlier than August 21, 2021. Firms are encouraged to begin using FINRA Gateway to draft Form U5 and provide feedback about the feature to FINRA.
Disclosure letters will become available in FINRA Gateway Requests May 1. FINRA encourages firms to begin using this feature and provide feedback to FINRA while disclosure letters are accessible in both Classic CRD and FINRA Gateway for the next several months. The ability to view disclosure letters in Classic CRD will be retired no earlier than August 21.
To learn more, register to attend the upcoming webinar on April 1.
FINRA will continue to publish updates in this space as information becomes available about the transition of registration filing activities from Classic CRD to FINRA Gateway. Additional information about managing registration compliance work in both systems can be found on the CRD is Moving to FINRA Gateway page.
Classic CRD Form U4 Retires April 5; Upcoming FINRA Gateway U4 Enhancements
Starting April 5, 2021, firms will be required to draft and submit Form U4 in FINRA Gateway. All other functionality within Classic CRD will remain supported. Firms that have not yet begun using FINRA Gateway to draft Form U4 are encouraged to do so. The Anonymous CRD Registered Representative site used to collaborate on Form U4 filings enabled with the Allow Rep Edits feature will also retire April 5, and Form U4 collaboration will be performed exclusively through FINRA Gateway and FinPro.
Additionally, several enhancements will be made to the FINRA Gateway Form U4 functionality over the next several weeks:
Available January 23:
- Draft Redlining: filers can use this feature to track differences between a draft Form U4 and the most recent submission on file for an individual.
- Print by Section: firms will be able to select the part(s) of the form they want included in a pdf or hard copy version of the draft.
- Allow Rep Edits & Other Feedback-Based Updates: thanks to input from firms, additional improvements will also be made to the following items:
- Allow Rep Edits workflow,
- keyboard navigation between form fields, and
- branch search while assigning an office location.
- Amend Archived Disclosure: FINRA Gateway will soon offer self-service retrieval of archived disclosure. Once available, firms will be able to update information without a support call or ticket.
More information about these and other system updates will be made available on the FINRA Gateway Release Notes page.
Form U4 resources, including webinar recordings, are available within the FINRA Gateway system as well as the new Form U4 page. We will continue to update firms on future Classic CRD functionality retirements in the coming months.
Classic CRD Form U4 Filing Capabilities Will Retire April 2021
Form U4 filing is available in both FINRA Gateway and Classic CRD. The Classic CRD Form U4 filing experience will be retired no earlier than April 5, 2021. As previously mentioned, firms are encouraged to prepare for the retirement of Classic CRD Form U4 filing capabilities by beginning to use the Form U4 filing functionality in FINRA Gateway now and providing feedback about their filing experience.
Firms that use the Allow Rep Edits feature should be aware that the Anonymous CRD Registered Representative site, along with its required reference code, will also retire in April. All Form U4 collaboration will be performed exclusively through the enhanced Allow Rep Edits feature in FinPro.
Information and resources for all three systems are available on the new Form U4 page, and additional support is available within the FINRA Gateway system. All other functionality within Classic CRD will remain supported and we will continue to update firms on future Classic CRD functionality retirements in the coming months.
Initial and Amendment Form U4 Filing Now Available in FINRA Gateway
On October 31, 2020, initial and amendment Form U4 filing functionality was released in FINRA Gateway. Additional Form U4 filing types will be made available November 21. We encourage firms to begin using the new online filing experience in FINRA Gateway and provide feedback while Form U4 is still available in Classic CRD. This implementation strategy is intended to provide sufficient flexibility for firms to test and transition to the new filing experience. Although firms can draft filings in both Classic CRD and FINRA Gateway, please be aware that a pending Form U4 can only be accessed on the platform that was used to initiate it.
Important Update Regarding the Form U4 Online Filing Experience
As part of our phased approach to building FINRA Gateway, we’ve actively sought firm feedback on how to improve the new compliance platform. Based on some of that feedback and in our continued efforts to deliver the most positive user experience, we are adjusting the previously announced launch of the online filing experience for Form U4 from October 5 to October 31. To support firm user transition, we will continue to offer current Classic CRD form filing functionality for an extended period of time after October 31.
Beginning October 31, FINRA Gateway users will be able to choose the new online filing experience for initial U4s and amendment U4s. All U4 filing types will continue to be available via Classic CRD. Once available, we encourage firms to use the new online filing experience in FINRA Gateway and provide us feedback as we work toward providing additional functionality.
Later in the year, firms will be able to submit the remaining U4 filing types (Relicense, Dual, Page 2, Concurrence) using the new online filing experience. All U4 filing types will still continue to be available via Classic CRD. We are planning to retire online filing of Form U4 in Classic CRD in the first quarter of 2021, and we will continue to collect feedback and work with firms to identify the retirement date of that functionality. Once a date is identified, FINRA will provide advance notice to firms (no less than 90 days).
We believe that this approach will provide firms flexibility and enable a successful transition to the new filing experience.
1. What is the objective of FINRA's filing experience enhancements?
FINRA is developing filing experience enhancements to make it easier for registration compliance staff and registered representatives to meet filing requirements. These improvements will encourage more accurate, complete and timely submissions, thereby reducing unnecessary (and sometimes costly) resubmissions. Additionally, the investing public who look to BrokerCheck and IAPD for registration information will benefit from more complete and accurate data.
2.What has changed with the enhanced U4 in FINRA Gateway? How does the enhanced U4 experience compare to the classic experience?
The legal Form U4 has not changed. Instead, FINRA has focused on improving aspects of the online filing experience for system users. The list below details some of the enhancements offered by the FINRA Gateway Form U4 filing experience:
- fully integrating the form with FINRA Gateway and FinPro
- streamlining the form initialization flow,
- eliminating the need to choose a specific U4 filing type,
- grouping thematic information together (e.g., display all personal information fields on a single screen as opposed to the four distinct sections of the legal form),
- providing more guided navigation so firms accurately answer only the questions that are relevant to a specific situation,
- strengthening validations to ensure the form is as complete as possible before submission,
- updating the functionality to query within the form for information already in the system, and
- integrating additional existing U4 interpretive guidance and definitions of terms throughout the form.
See the Enhanced Form U4 Filing Experience Summary of Changes for an in-depth, side-by-side comparison of the Classic CRD and FINRA Gateway Form U4 filing capabilities.
3. How do I start a U4 filing in FINRA Gateway?
Begin by searching for an individual in FINRA Gateway and viewing their profile. The Actions section of the individual’s profile will contain links for the filing types that are available for that person. For individuals not already associated with your firm, use the Pre-Registration search option in FINRA Gateway.
4. Where can I see pending filings using the new online filing experience in FINRA Gateway?
Draft U4 filings created in FINRA Gateway can be accessed in the Requests feature in FINRA Gateway. You can also see any pending U4 filings in the Drafts section of an individual’s profile.
5. Where can I see submitted filings (filing history)?
All submitted filings, regardless of where the filing was created, will continue to be available in the individual’s filing history in Classic CRD. Similar functionality is being developed for the FINRA Gateway Profiles feature and will become available soon. See the CRD is Moving to FINRA Gateway page for more dates and details.
6. How do I work simultaneously with my representatives on U4 filings using the Allow Rep Edits feature?
Effective April 5, firms can enable the Allow Rep Edits feature in FINRA Gateway so that individuals can work simultaneously on U4 filings through FinPro. The Allow Rep Edits feature was improved for firms and individuals alike as part of the Form U4 enhancements. The Enhanced Form U4 Filing Experience Summary of Changes and Form U4 in FinPro pages explain how to enable and use Allow Rep Edits in FINRA Gateway and FinPro.
7. What is the impact to automated U4 submissions through Web EFT?
There are no changes to Web EFT schemas or technical specifications.
8. Will FINRA provide a similar parallel process for the introduction of other CRD forms?
When possible, other CRD forms will be released in FINRA Gateway in a similar fashion (i.e., firms will be able to submit filings in both Classic CRD and FINRA Gateway for a period of time). Details will be provided as additional forms are developed for FINRA Gateway.