Registration Filing in FINRA Gateway
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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?
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 has changed with the enhanced U4 in FINRA Gateway?
The legal Form U4 has not changed. Instead, FINRA has focused on improving aspects of the online filing experience for system users. See the Enhanced Form U4 Filing Experience Summary of Changes for an in-depth comparison of the Classic CRD and FINRA Gateway Form U4 filing capabilities.
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.
3. How does the enhanced U4 experience compare to the classic experience?
Please refer to the Enhanced Form U4 Filing Experience Summary of Changes for a side-by-side comparison of the different filing experiences.
4. 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.
5. 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. FINRA Gateway pending filings are available via the Requests feature, and Classic CRD filings are available via the Pending U4 Filings section from the site map in the Classic CRD system.
6. Where can I see submitted filings (filing history)?
All submitted filings, regardless of the data entry type used, will be available in Classic CRD.
7. Should representatives use the reference code or FinPro approach for collaborating on the U4 filing with Allow Rep Edits functionality?
A representative’s Allow Rep Edits access options are dictated by the system that their firm used to initiate the draft submission:
Classic CRD: Representatives have the option to access the filing through FinPro or the Anonymous CRD Registered Representative site. See the Classic CRD Form U4 Quick Reference Guide for step-by-step instructions. The Anonymous CRD Registered Representative site will be retired April 2021 in conjunction with Form U4 filing functionality in Classic CRD.
FINRA Gateway: Representatives must use the Financial Professional Gateway (FinPro) to retrieve and enter information on a draft Form U4 initiated in FINRA Gateway. As part of the enhancements for the FINRA Gateway Form U4 filing experience, the Allow Rep Edits feature was improved for firms and registered individuals alike. The Enhanced Form U4 Filing Experience webinar demonstrates the process of enabling and using Allow Rep Edits in FINRA Gateway and FinPro.
All collaboration with representatives will be performed exclusively via FinPro after Form U4 is retired in Classic CRD.
8. Will the reference code access option for the Allow Rep Edits feature remain available?
No, the Anonymous CRD Registered Representative site and related reference code access option will be retired when the Classic CRD Form U4 filing experience retires in April 2021.
9. When will FINRA retire the ability to file Form U4 in Classic CRD?
Form U4 filing in Classic CRD will retire April 5, 2021. FINRA is committed to monitoring and adjusting the transition to the FINRA Gateway Form U4 filing experience as appropriate. Firms are encouraged to provide feedback and participate in user research opportunities to help inform the design of features and tools in FINRA Gateway.
10. What is the impact to Web EFT submissions?
11. Will FINRA provide a similar parallel process for the introduction of other CRD forms?
FINRA will work to ease the transition for all future forms. When possible, other CRD forms will be released in FINRA Gateway in a similar fashion (i.e., firms will be able to draft 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.