Registration Filing in FINRA Gateway
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.
Frequently Asked Questions
1. What is the objective of FINRA's filing experience enhancements?
To make it easier for firm compliance and registration staff to meet registration filing requirements, as well as reduce the learning curve for new financial professionals. We heard from firms there was room to improve the workflow for small amendments and bulk changes, so we are developing tools to handle these items more efficiently. In addition to improving the filing experience, we hope it 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 will change with the enhanced U4?
The legal Form U4 will not change as part of this release. Instead, FINRA has focused on improving the following aspects of the online filing experience for system users:
- 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.
3. If I have a pending U4 which was started using classic CRD, can I complete it using the new online filing experience in FINRA Gateway? If I have a pending U4 which was started using the new online filing experience in FINRA Gateway, can I complete it using classic CRD?
No. Filings begun either in classic CRD or the new online filing experience in FINRA Gateway must be completed entirely using a single method.
4. Where can I see pending filings using the new online filing experience in FINRA Gateway? Where can I see pending filings using the classic CRD experience?
Pending filings are stored with each method (new online filing experience in FINRA Gateway, classic CRD via Pending U4 Filings from the Site Map).
5. Where can I see submitted filings (filing history)?
All submitted filings, regardless of the data entry type used, will be available in classic CRD.
6. Can I direct my representatives to the reference code or FinPro approach for collaborating on the U4 filing with Allow Rep Edits functionality?
For all filings that are completed using the classic CRD filing experience, firms can direct their professional to use either the reference code approach or FinPro.
Filings made using the new filing experience require the professional to use FinPro for collaborating with Allow Rep Edits functionality.
7. Will the reference code model of representative collaboration ("Allow Rep Edits") be retired at the same time as the classic CRD U4 filing experience?
8. What is the impact to Web EFT submissions?
9. Will FINRA provide a similar parallel process for the introduction of other CRD forms?
FINRA will work to ease the transition to all future forms. More to come on how this will be achieved.