IARD Publications - IARD Bulletin

IARD Bulletin
March 2002

Revised: 04/01/02

Table of Contents

Introduction

This issue of the IARD Bulletin is focused on the electronic registration of investment adviser representatives (RA registration position) utilizing the Web CRD^SM functionality to process RA position requests. The first Web CRD software release of 2002, Release 4.0, implements the electronic registration of investment adviser representatives for both joint broker/dealer-investment adviser firms and investment adviser-only firms, along with other changes and enhancements to the Web CRD System. In conjunction with this Release, revised versions of the Uniform Forms U-4 and U-5 are also being implemented. The forms have been revised not only to incorporate the new investment adviser representative registration position, "RA", but also to align them more with their electronic counterparts in Web CRD. The changes are intended to make the forms more user-friendly for firms and their associated individuals. Please be sure to read the Changes to the Uniform Forms outlining the changes to the forms later in this Bulletin for more detailed information. You can view and/or print the revised forms on the NASDR Web Site.

To assist you, as you become accustomed to the electronic registration process of investment adviser representatives, we have updated the user support tools available on this Web Site which are located in the User Support menu item. Please refer to the user support tools such as the revised Firm User's Manual and IARD Navigation Guides as you familiarize yourself with the individual registration process on Web CRD. Additional user support is covered later in this Bulletin.

What's New in Web CRD for Investment Adviser Firms and Joint B/D-IA Firms in Release 4.0?

Investment Adviser Representative (RA) Transitioning

New link on the Web CRD Site Map in Individual Non-Filing Info for IARD Transition Registration.
- This functionality allows your firm to transition existing investment adviser representatives (RAs) onto Web CRD. The system will not let a non-IA firm transition an individual.
- The General CRD Search Screen will be available. Firms will be able to create an individual record if the individual is not in Web CRD.
- Office of Employment address fields will appear if the individual is not associated with the firm.
- Check boxes for transitioning registrations will be disabled if the firm is not registered as an IA with the jurisdiction, or if the individual has previously transitioned with the firm and regulator combination
Joint B/D-IA firms may choose to do a batch filing (electronic file transfer) for transitioning multiple individuals currently registered through CRD. For details regarding batch transitioning, joint B/D-IA firms may contact the Gateway Call Center at (240) 386-4848.

Individual Queues

New Other Firm U4 Filing Queue
- If an individual is dually registered with your firm and another firm, this Queue notifies your firm of any U-4 Filing submitted by the other firm for this individual.
- You can view the U-4 Filing submitted by the other firm and submit the new Concurrence Filing to concur with the shared information or submit a U-4 Amendment Filing.
New search filter added to the Queues: "CRD Only," "IARD Only," and "Both".
Firm users are now able to retrieve Fingerprint Status Received from FBI Notice Queue with FBI statuses for all individuals at once.
Added a new queue, Delinquent U-5 Notice Queue, which displays individuals who started employment with a new firm, however, your firm has yet to submit a U-5 Filing for the individual.
Queue Total Pages updated to show subtotals for registered representatives (AG) and investment adviser representatives (RA).

Organization Queues

Added "paging" to the Organization Queues.

Organization NFI - Firm Notification

New firm e-mail notification option in Maintain Firm Notification Info to notify you when a registered individual enters the "Other Firm U4 Filing Queue".

Accounting

3 new System Fees for investment adviser representatives (RAs):
- Initial Set-Up Fee (one time) - $45
- Annual Fee (charged during Renewals) - $45
- Transfer Fee - $45

View Individual

RA position is viewable in Registration with Current Employers and Registration History Details.
Request Snapshot is available on the View Individual Navigation Bar.
Type of Employment (registered representative, investment adviser representative) will be indicated on the Composite Information Screen.
Message will appear if the individual is registered with multiple firms on the Composite Information Screen.
New section for Professional Designations.
New Material Difference Flag in Composite and Disclosure. For dually registered individuals, this flag indicates a difference exists in U-4 DRP details for the same disclosure event.

View Organization

Revised Branch Office Search will let firm retrieve all branches and page through the list.

Form Filing

Pending Filings: All "pending" U-4 and U-5 Filings became "read only" on March 18, 2002, with Release 4.0 implementation. Firms should re-enter information post Release.
Historical Filings: Redlining will not be visible for the first filing of the Forms U-4 and U-5 submitted for each individual after the Release is implemented due to the changes resulting from the revision of those two forms. Redlining will be visible on all filings subsequent to the first non-redlined filing by the same firm.
Form U-4:
- New Navigation Bar with new form sections.
- Versioning of forms will exist in Filing History.
- New Private Residence Check Box in General Information.
- New section in Fingerprint Information for IA-only applicants.
- A single filing to register with Affiliated Firms, both BD and IA.
- New section for Registration with Unaffiliated Firms, which clarifies dual registration.
- Expanded system checks on Dual Registration.
- RA Positions are activated in the Jurisdiction Registration section.
- New section for current Professional Designations for RAs.
- 3 new Relicensing Filing Types:
  - Relicense All Registrations: Choose this type if the applicant wishes to register with your firm within 30 days from the date of termination with ALL previous firms with which he/she has been working, and intends to be SOLELY with your firm.
  - Relicense Only CRD Registrations: Choose this type if the applicant wishes to register as a Broker/Dealer Agent (AG) with a new firm and wishes to terminate his/her AG positions with any other firms, but leave any Investment Adviser associations he or she may have current.
  - Relicense Only IA Registrations: Choose this type if the applicant wishes to register as an investment adviser representative (RA) with a new firm and wishes to terminate his/her RA positions with any other firms, but leave any Broker/Dealer associations he/she may have current.
- New Concurrence Filing Type. This filing type allows you to "concur" with the information filed by the other firm with whom the individual is registered by submitting a Concurrence Signature Page. This "read only" filing type is used when a firm is notified in its Other Firm U4 Filing Queue that a U-4 Filing was submitted for an individual dually registered with your firm and another firm. The system will display the appropriate form filing link dependent on which information was updated. An Amendment Filing link will display for all U-4 Filings, while the Concurrence Filing link will only display when individual specific information has changed. The links will begin a new form filing for that U-4 filing.
- Revised Signature Page with additional Signature blocks for the applicant and firm.
- Relaxed Completeness Checks for NRF Filings will allow firms to easily close out any non-registered individual records.

Form U-5

Full or Partial Terminations for RA registrations.
Option to terminate RA registration with an affiliated firm.
Signature block and Acknowledgement & Consent for individuals in Section 2.

Reports

New Transition Report (Individual Transition Status-Firms) will be available for firms to request.
Individual Snapshot Report can be generated using either Social Security Number or CRD Number.

Minimum Recommended Hardware/Software Configuration Upgraded for Web CRD and IARD

Modem: 56 KB (28.8KB minimum)

Web Browser: Microsoft Internet Explorer 5.0 or greater
Netscape Navigator 6.1 or greater (Javascript enabled)

Screen Resolution: 1024 x 768 (800 x 600 minimum)

Users can update the most current version of Microsoft Internet Explorer or Netscape directly from Web CRD:

From the Site Map, click on User Information > "Recommended Hardware/Software"

Click on the appropriate logo on the "Minimum Recommended Client Configuration" screen

Web CRD Entitlement For Investment Adviser Representative Filing

With the implementation of investment adviser representative (RA) registration via the Web CRD System, IA firm users will now require entitlement to certain Web CRD user privileges in order to submit Form U-4 and Form U-5 filings and perform the necessary follow-up regarding those filings. Firm Account Administrators have the ability to provide users in your firm with updated entitlement privileges to include IA representative registration functions; however, NASDR must receive a new Account Administrator Entitlement Form (AAEF) from Firm Account Administrators that wish themselves to be entitled to investment adviser representative functions.

Firm Account Administrators who wish to be entitled to functions performed for investment adviser representatives (IA representative) should contact the IARD Hotline at (240) 386-4848, to request that a new Account Administrator Entitlement Form (AAEF) be faxed to them. Check the applicable IA representative entitlement privileges needed. Once the form is completed, fax it back to NASD Entitlement at (240) 386-4669.
- Please note: If you are a sole proprietor, then you are most likely the Account Administrator for your firm and you should also submit a new AAEF.
Firm Account Administrators have the ability to update the entitlement privileges of the users in your firm by following these steps:
- From the IARD or Web CRD Site Map under Admin Tools, click on 'Change Password'
- Along the left navigation panel under User Account Functions, click on 'Edit Account'
- Click on the arrow to get the drop down box and select the user you want to update privileges for and then click on 'Account Options'
- Select the applicable IA representative related privileges you want to add for this user which might include some or all of the following listed under the Web CRD category:
  - Form Filing (Form U4/U5)
  - Individual Processing
    - Queue Approve/Remove all
    - Firm Queues
    - Non-Filing Information
    - IARD NFI Transition Registrations
    - View Individual Information
  - Maintain Firm Notification (includes new notification - 'Other Firm U4 Filing Queue')
- Once you have selected the applicable privileges, click on 'Save Account Options'
- Please Note: The new Web CRD privileges you mark for your users will only appear to them on the Web CRD Site Map, not the IARD Site Map.

IARD entitlements remain the same and should only be updated if a user's role and responsibilities have changed.

Additionally, both the Web CRD and IARD Terms and Conditions are now presented on each system, Web CRD and IARD, as the user signs on, and the user must accept both before having access to either system.

State Participation and Exemptions of the Electronic Registration of Investment Adviser Representatives

There are seven states that do not currently register investment adviser representatives (RAs): Georgia, Louisiana, Michigan, Minnesota, New York, Tennessee, and Wyoming. Some states provide an exemption from investment adviser representative (RA) registration if you are also a registered representative. The North American Securities Administrators Association (NASAA) has compiled a matrix of these states on its Web Site, along with contact information for each of the states. If you are unsure as to the requirements of the state when it comes to investment adviser representative registration (RA), please contact the state for clarification before submitting the electronic filing.

It is important for you to be fully informed and knowledgeable about these non-participating states as the System Processing Fees, $45 per individual for Transition Filings or Initial Filings, are non-refundable if you should submit an electronic filing for an individual in error.

Therefore, as you are transitioning your investment adviser representative (RA) registration information onto Web CRD, or if you are filing an Initial Form U-4 to request registration for an investment adviser representative for the first time in a state, be aware of these states and make sure that before you submit your filing, you are certain that you must file in the state. Some of these states will require you to file and others won't.

New Investment Adviser Representatives

IA firms will be able to electronically register new individuals applying for positions as investment adviser representatives (RA) on Web CRD with the implementation of Release 4.0 on March 18, 2002. IA firms should utilize this online capability to register individuals as directed/mandated by state(s) or on a voluntary basis. Representatives of investment advisers, broker/dealers, or issuers of securities must use the Form U-4 to become registered in the appropriate jurisdictions and/or SROs. In section 5 (Jurisdiction Registration) of the revised Form U-4, a new position code, Registered Adviser (RA), will be available for individuals seeking registration as investment adviser representatives.

Please note that in order to access Web CRD, IA-Only firms will first need to request system entitlement from NASDR. Details regarding the entitlement process are outlined in this Bulletin's article titled "New Web CRD Entitlement for IA-Only Firms."

The URL Address for CRD is https://crd.nasdr.com/CRDMAIN.

The Individual Form Filing functionality in Web CRD will provide the ability to create an Initial Form U-4 Filing. Once you have logged onto Web CRD, from the CRD Site Map in the Forms section, look under the U4 Form section and select either 'Create New U4 Filing' or 'Initial.'

For detailed instructions on how to create an online Initial Form U-4 Filing for individuals registering as investment adviser representatives, visit the IARD Web Site and print the following two sources available under the "User Support" menu item:

Transitioning Currently Registered Investment Adviser Representatives

The 4.0 Release enables Investment Adviser firms to electronically register their investment adviser representatives (RAs) through CRD using the revised (03/2002) Form U-4. IA firms will be able to register RAs electronically as directed/mandated by state(s) or on a voluntary basis. However, before an IA firm files it first electronic Form U-4 for an existing RA, the firm must update CRD to reflect the states with which the RA is currently registered. This process is called submitting a "Transition Filing." Transitioning only applies to existing investment adviser representatives (RAs) who are already registered or licensed in states. By submitting a Transition Filing, a firm ensures that it is not charged for state registration fees it has previously paid before implementation of the RA functionality. A one-time, non-refundable Initial Set-Up Fee of $45 is charged per individual when a firm either transitions a currently registered RA or submits a Form U-4 Filing for a new applicant.

IA-Only firms or Joint Broker/Dealer-Investment Adviser firms should submit individual Transition Filings through the Non-Filing Information (NFI) function in Web CRD. Account Administrators should make sure that individuals at the firm performing the Transition Filings have been entitled to the privilege (NFI-IARD Transition Registrations). The Transition Filing will:

Identify states where the RA is currently registered
Provide basic employment information about the RA
Create a CRD Number if none exists for the individual

Submitting the Transition Filing will pre-populate CRD with the investment adviser representative's record of all state registrations for those states that participate. At this time, the investment adviser representative's (RA) registration status is TRANS_RQST (Transition Requested). The Transition Filing appears in a state's Individual Transition Approval Queue where the state(s) will validate the registration(s) and enter the date the individual first became registered in that state. Subsequently, the RA registration status in CRD will reflect the investment adviser representative's current registration status in each state.

Once a Transition Filing has been submitted, the firm can submit an electronic Form U-4 Amendment Filing for the investment adviser representative. As a guidance, a Form U-4 Amendment should be submitted for the individual within 30 days from the date of the Transition Filing if the individual doesn't have a "current" U-4 Filing in CRD. Jurisdiction(s) with which the investment adviser representative transitioned, should be contacted for the specific filing time. (There is a State IA Directory at the end of this Bulletin). The firm does not have to wait for the state approval of the Transition Filing before submitting the Form U-4 Amendment Filing.

There are two ways to transition investment adviser representatives onto Web CRD:

Online Individual Transition Filing
- Process available for either IA-Only firms or Joint B/D-IA firms
Batch Transition Filing (Electronic File Transfer)
- Process available only for Joint B/D-IA firms

Online Individual Transition Filing

For IA-Only firms (including firms affiliated with NASD members that are registered as IA-Only), there is no record in Web CRD of the firm/individual(s) association. In fact, most of the individuals registered with IA-Only firms have never had a CRD record. As a result, the Transition process for these individuals will require the firm to establish a new CRD record for each individual and then indicate on the system the states with whom the individual is registered. Based upon the firm entering the information, the system will create an electronic "base" record for the individual, which will set up the firm/individual association and record the appropriate registrations for the states to confirm.

There are two ways to access IARD Transition Registration in Web CRD:

From the Site Map, click on IARD Transition Registration Search
or
Click the Individual Tab from the Tool Bar, choose Non-Filing Info from the sub-menu and click IARD Transition Registration Search from the Navigation Bar or Footer.

Note: The user must be entitled to the IARD NFI Transition Registrations privilege in order to submit an online Transition Filing.

Note: If the IA representative (RA) has a CRD Number, the firm can select him/her from CRD and submit.

For detailed instructions on how to create an online Transition Filing for a currently registered investment adviser representative, visit the IARD Web Site and print the following two sources available under the "User Support" menu item:

Batch Transition Filings

The "Batch Transition Filings" or electronic file transfer method of transitioning groups of investment adviser representatives is available only for firms who are registered as both a broker/dealer and an investment adviser firm (Joint firm). Because the individuals associated with a joint B/D-IA firm already have an active CRD record with the firm as registered representatives, the firm need only indicate to the system the states with whom these are registered individuals. Depending on the number of IA representatives (RAs) that a Joint B/D-IA is required to transition, Batch Transition Filing may be a better alternative to submitting individual Transition Filings.

Process Overview

There is no minimum headcount required to submit a Transition Batch File. Each firm should assess the effort in relationship to the number of IA representatives (RAs) the firm has to transition in order to determine if they should participate in "batch" Transition Filing. The firm sends NASD a file containing XML-based IA representative (RA) transition data.

A nightly job will process the files. The system will validate the file and each "row" of data within the file, recording the errors to a result file. After processing, the results file will be emailed to the submitting firm. The results file will report statistics on success and failure as well as specifics for any errors. Batch file transmissions should exclude IA representatives (RAs) in state(s) that direct you not to transition.

During the processing, investment adviser Transition Filings will be created for each of the valid individual/organization/regulator combinations in the file. The processing of the requests will be the same as if the request was made online via the "NFI Transition Registration Request" in Web CRD.

For successful processing of the Transition Batch File, firms should:

Have a "sufficient" Daily Account status in their firm's IARD/CRD financial account
Have an "active" IA status in IARD (Notice or Registration)
Have an "active" registration(s) with the regulator(s) selected
Make sure that the IA representative (RA) has an "open" RR employment with the firm in Web CRD
Exclude IA representatives (RAs) in state(s) that direct you not to transition

Scheduling of Transition Batch File

In order to address the workload that the states will have as firms transition large numbers of investment adviser representatives onto the system, an electronic filing submission schedule is being coordinated and managed between NASD, the states and the firms that will balance the batch files. Firms that wish to complete their transitioning obligations in this manner should contact the Gateway Call Center at (240) 386-4848 in order to obtain the "Batch Transition Registrations" specifications. As part of the batch filing process, the system will validate a number of data elements and perform a number of checks. The batch file transfers are anticipated to be executed through June 2002.

Who Should Not Transition

Transition Filings for investment adviser representatives (RAs) should not be submitted for:

New individuals registering as IA representatives (RA position)
IA representatives (RAs) in state(s) that direct you not to transition
IA representative (RAs) in a state that does not register them

Check the NASAA Web Site for information and guidance or contact the state directly.

What Happens As a Result of Transition Filing?

A $45 Initial Set-Up Fee is assessed from the firm's Daily Account for each individual that the firm transitions. It is assessed at the time the filing is processed and is non-refundable.
The IA representative (RA) has a base electronic registration record in CRD.
An electronic notification is sent to the state's Jurisdiction Transition Approval Queue.
The states then:
- Verify the investment adviser representative's (RA) current registration,
- Provide the IA representative's (RA) "original" approval date on CRD,
- Change the IA representative's (RA) registration status from "Transition Requested" to "Approved"
  - If the firm is "pending," the IA representative's (RA) status will change to "Deficient-Pending Firm"
  - If the firm submits an incorrect Transition Filing, the status will be changed to "Transition Filed in Error"

Tips for Transitioning Investment Adviser Representatives (RAs)

Be sure that your financial account status is "Sufficient" before attempting to do a Transition Filing.
Be sure that your Account Administrator has entitled you with the following privilege: Web CRD > Individual Processing > Non-Filing Information > NFI IARD Transition Registrations.
If you are an Account Administrator who wishes to be entitled to investment adviser representative registration functions in Web CRD, you must call the IARD Hotline at (240) 386-4848, to request a new Account Administrator Entitlement Form (AAEF) to be faxed to you. Fax the completed form to NASD Entitlement at (240) 386-4669.
Before you submit a Transition Filing, check the NASAA Web Site for information pertaining to states that exempt IA representatives (RAs) from registration or check with the regulator directly.
A Transition Filing cannot be saved as a "Pending" Filing. If you start a Transition Filing and do not complete and submit the filing, any data you have entered will be lost and a new Transition Filing must be created and submitted.
You can submit a Form U-4 Amendment Filing updating information for an IA representative (RA) before a state approves the Transition Filing, i.e., while the IA representative's (RA) registration status is TRANS_RQST (Transition Requested).
If you are a joint B/D-IA firm and plan to transition your IA representatives (RAs) via a batch transition file, contact the Gateway Call Center to get the file specifications, have your sample file tested, and schedule the submission of your file.
Once a Transition Filing has been submitted, a Form U-4 Amendment should typically be submitted for the individual within 30 days of the Transition Filing if no current Form U-4 is on file in CRD. The jurisdiction(s) with which the investment adviser representative transitioned should be contacted for specific time guidelines.
In order to prevent filing errors, IA representative (RA) checkboxes for transitioning registrations will be disabled if:
- The firm is not registered as an IA with the jurisdiction
- The individual has previously transitioned with that firm/regulator combination
- The state does not register investment adviser representatives
- The state is not participating in the electronic registration of investment adviser representatives
If a state where the IA firm is registered, mandates that its investment adviser representatives (RAs) must electronically file via the system, the firm should consider electronically filing for all of it's IA representative (RAs) in all states that participate. Electronic filing in Web CRD offers numerous advantages for firms:
- One filing and one renewal payment for most states
- Easy access to a central registry of all of the firm's information
- Cost and time savings due to the elimination of paper filings

System Fees for Investment Adviser Representatives
The electronic registration of investment adviser representatives (RAs) was implemented with Web CRD Release 4.0. Associated with that are three new system processing fees for all investment adviser representatives that you plan to register electronically. These fees will be non-refundable and are as follows:
Initial Set-up Fee: $45

This one-time fee is charged when your firm transitions an existing investment adviser representative (RA) onto Web CRD to create a base electronic record of his/her registration.

For a new registrant, this one-time fee is charged when your firm electronically files an Initial Form U-4 for the new investment adviser representative (RA).

Annual Fee: $45

This fee is charged once a year during the Renewals Program for each investment adviser representative with your firm and covers all electronic filing activity for the next year.

Transfer Fee: $45

This fee is charged when an investment adviser representative changes his/her registration from one firm to another, electronically via Web CRD.

Accounting for Investment Adviser Representative Filing Processing

The Daily Account is the primary account to which your firm deposits funds to allow for day-to-day transactions to occur. Your firm's Daily Account Status is defined as either Sufficient or Deficient throughout a business day. Your Account Status will remain the same for the entire day, regardless of any payments or withdrawals made during that day. Payments or withdrawals are not reflected in your Daily Account Status until the next business day after the payment is received. When you check your Account Status, you will see that your account is either:

Sufficient with a Credit Balance:

A credit balance is a favorable balance for your firm. It indicates a Sufficient Account Status. A credit balance is displayed as a negative amount. For example, an outstanding credit balance of $-1,000.00 represents funds of $1,000.00 available to pay for transactions.

or Deficient with a Debit Balance:

A debit balance is an unfavorable balance for your firm. It indicates a Deficient Account Status, which means your firm has no funds available to pay for transactions. Your firm should deposit funds into the account to cover the amount of the debit balance. A debit balance is displayed as a positive amount. For example, a debit balance of $1,000.00 represents that your account is deficient for that amount.

Investment Adviser-Only Firms

Form U-4 Filings can be submitted in CRD if the IA firm's Daily Account Status is Deficient; however, no transactions will be processed for that day, i.e., IA representative (RA) registration requests will be deficient funds and exams will not schedule.
IA representative (RA) registration requests will be deficient for fees if sufficient funds are not available in the firm's Daily Account at the time of the filing.
Transition Filings cannot be submitted if the Account status is "Deficient".
For Form ADV submissions in IARD, the firm needs at least the exact dollar amount required of the filing in order to submit the filing. If not, the ADV Filing will fail the completeness check.
All financial account information can be viewed from a firm's Daily Account from Web CRD or IARD.

Broker/Dealer-Investment Adviser (Joint) Firms

Fees for investment adviser representatives (RAs) will be applied identically to how registered representative fees apply in Web CRD. Registration requests will be deficient for fees if sufficient funds are not available in the firm's Daily Account at the time of the filing.
Form U-4 Filings can be submitted on behalf of investment adviser representatives if the Joint firm's Account Status is "Deficient", however, no transactions will be processed for that day, i.e., IA representative (RA) registration requests will be deficient funds and exams will not schedule.
Transition Filings cannot be done for the investment adviser representative if the account status is "Deficient."
For Form ADV submissions in IARD, the firm needs at least the exact dollar amount required or more in its Daily Account in order to submit the ADV filing. If not, the ADV filing will fail the Completeness Check.
All financial account information can be viewed from a firm's Daily Account from Web CRD or IARD.

In order to ensure daily processing activity for your filings, be sure to maintain sufficient funds in your financial account to also cover the System Processing Fees associated with your filings. Remember to also include them in your budgeting process.
System Processing Fees
All System Processing Fees are non-refundable. Therefore, it is important to make sure that an electronic filing must be submitted for the investment adviser representative. If you are not certain, contact the state directly before making the filing.
The System Processing Fees for investment adviser representatives are:
Initial Set-up Fee: $45
This one-time fee is charged for each investment adviser representative who transitions onto Web CRD when a Transition Filing is processed or for each new registrant when an electronic Initial Form U-4 is filed.
Annual Fee: $45
This fee is charged once a year during the Renewals Program for each investment adviser representative with your firm and covers all electronic filing activity for the next year.
Transfer Fee: $45
This fee is charged when an investment adviser representative changes his/her RA registration from one firm to another electronically via Web CRD.

Qualifying As An Investment Adviser Representative (RA Registration Position)

If you are seeking registration as an investment adviser representative (RA registration position), you may qualify in several ways. The Web CRD System facilitates the qualification process for investment adviser representatives and supports the business requirements of state regulatory agencies. There are several ways, in the system, in which an individual may qualify for an RA registration. To be deemed qualified as an IA representative (RA registration), the system requires that an individual meet one of the following criteria:

Have a passing grade for the Series 65 (S65) Exam within the past two years; or
Have a passing grade for the Series 66 (S66) Exam with the past two years and a passing grade for the Series 7 (S7) within the CRD continuous registration period or two years prior to the beginning of the continuous registration period; or
Have a passing grade for the S66 Exam with the past two years and a GS/TR/TS within the CRD continuous registration period; or
Currently hold one of the system recognized Professional Designations; or
Have held an approved IA representative (RA) registration with any jurisdiction within the past two years.

If you are deemed qualified by the system by meeting criteria 1, 2 or 4, your RA registration will automatically approve in states who have chosen the "Automatic" Review Method.
If you are deemed qualified by the system by meeting criteria 3 or 5, your RA registration request will be forwarded to the state's "Waivable Deficiency Queue" for the state to make the determination. This rule applies to all states whether they utilize the "Manual" or "Automatic" Review Method. While the registration request is in the state's "Waivable Deficiency Queue," the IA representative (RA) registration status for the state will be "Pending."

What this equates to, in business scenarios is:

If you have an existing valid IA representative (RA) registration in a jurisdiction and you are transferring to a new firm within the same jurisdiction, check the appropriate jurisdiction box (Section 5 of the U-4 Filing). Do not request an examination you have already passed because you will not be required to retake the examination.
If, within the past two years, you held or currently hold an approved IA representative (RA) registration in any jurisdiction, your registration may reciprocate in the new jurisdiction(s) in which you seek registration without an examination. Check the box (es) for the jurisdiction(s) in which you are seeking registration. Do not request an examination. Your registration request will go to the state to determine if you qualify for reciprocation in that state. Your RA registration status will be "Pending" until the state's review is complete.
If you do not maintain an existing IA representative (RA) registration or you are not already qualified for the RA registration requested, you may qualify by (1) passing the Series 65 (S65) Exam, or (2) passing both the Series 7 (S7) and Series 66 (S66) examinations.
- Qualifying by passing the Series 65 (S65) Exam
  - If you are otherwise unqualified, a Series 65 (S65) Exam should be requested if:
    - The registrant does not currently (or within the last two years) maintain a valid IA representative (RA) registration.
    - The registrant neither holds a professional designation nor meets any exam qualification requirements.
    - The registrant has only met one examination requirement of the combination S66 and S7 exam qualification and does not choose to schedule the co-requisite exam with the submitted filing.
- Qualifying by passing both the Series 7 and Series 66 Exams ("Joint" Broker/Dealer-Investment Adviser Firms only may use this method for qualification).
  - If you wish to qualify with a combination of the S7 and the S66 Exams, check the S66 Exam box. By checking the S66 Exam box, the S66 Exam will be scheduled and a 'Developed A Need' status for the S7 Exam will result. You must then submit a U-4 Amendment requesting the S7 Exam be scheduled. The S7 Exam may only be taken by IA representatives (RAs) who are also registered with NASD member firms.
  - If you wish to qualify with this exam combination but want to schedule the S7 or S66 Exam at a later date, you must make another filing to request that exam.
    - (Note: The two exams are co-requisites and states require successful completion of both exams prior to granting your IA representative (RA) registration.)
- A Series 7 (S7) Examination will result in a 'Developed A Need' status if only a S66 exam is requested, but the individual does not hold a GS/TR/TS position within the CRD continuous registration period. The system's "Developed A Need" status to the individual's record will explain the requirement of the scheduling of the co-requisite exam. (IA-Only Firms, Please Note: Only "Joint" B/D-IA firms may schedule a Series 7 Exam; therefore, if an IA-Only Firm follows this route, the S66 Exam will be scheduled, the firm will be charged for it; however, the firm will not be able to schedule a S7 for the IA representative (RA). The IA representative (RA) will have to then schedule and pass the S65 Exam.)
In addition, many jurisdictions participating in the electronic registration of IA representatives have indicated that they will accept certifications from professional designating authorities as a basis for waiving an exam requirement or to serve as an alternate qualification. Therefore, if you currently hold one of five designations (CFP, ChFC, PFS, CFA, CIC) and it has been uploaded into CRD by the designating authority then the Form U-4 Filing will pass the system Completeness Check. You should check the requirements of the jurisdiction(s) in which you are seeking registration before completing the U-4 Filing.
- If you wish to request to qualify for an IA representative (RA) registration using any of the five professional designations (CFP, ChFC, PFS, CFA, CIC), check the box(es) in Section 8 of the U-4 Filing next to each designation you currently maintain.
  Please see the Professional Designations article in this Bulletin for additional details.

IA Representative (RA) Qualifications

To be deemed qualified for an IA representative (RA) registration, the system shall require that an individual meet one of the three following criteria.

Individual maintains an existing IA representative (RA) registration:
- The individual has a valid existing IA representative (RA) registration in the jurisdiction¹ and is transferring to a new firm within the same jurisdiction; or,
- The individual has held an approved IA representative (RA) registration within the past two years in any jurisdiction
Individual is qualified through examination with one of the following:
- The individual has taken the Series 65 (S65) Exam with a passing grade within the past two years
- The individual has taken the Series 66 (S66) Exam with a passing grade within the past two years and the Series 7 (S7) Exam with a passing grade within the CRD continuous registration period
- The individual has taken the S66 Exam with a passing grade within the past two years and the S7 Exam with a passing grade within two years prior to the beginning of a continuous registration period
- The individual has taken the S66 Exam with a passing grade within the past two years and has a GS/TR/TS within the CRD continuous registration period²
Individual is seeking an IA representative (RA) registration and holds one of the following professional designations as a basis for waiving the exam requirement or to serve as an alternate qualification:
- CFP - Certified Financial Planner
  - Awarded by the Certified Financial Planner Board of Standards, Inc.
- ChFC - Chartered Financial Consultant
  - Awarded by the American College, Bryn Mawr, Pennsylvania
- PFS - Personal Financial Specialist
  - Awarded by the American Institute of Certified Public Accountants
- CFA - Chartered Financial Analyst
  - Awarded by the Association for Investment Management Research
- CIC - Chartered Investment Counselor
  - Awarded by the Investment Counsel Association of America, Inc.

Note: Firms with individuals that hold the Personal Financial Specialist (PFS) designation with the AICPA and/or the Chartered Financial Analyst (CFA) designation with AIMR must contact the respective designating authority in order to have their information forwarded to Web CRD if they wish to request to qualify as an IA representative (RA registration) with one of these professional designations. For additional information regarding the CFA professional designation, please visit the AIMR Web Site at: www.aimr.org/pdf/adv_waiver.pdf

RA Examination Fees

Exam Fee

Series 65 $110

Series 66 $110

Series 7 $200

¹ An RA's qualification requirements may vary for each state, which is why the state review method will be set to the "Manual" Review Method for individuals that qualify due to an existing RA registration.

² The state review method will also be "Manual" for individuals that qualify by having passed the Series 66 (S66) Exam in the past two years and hold a GS/TR/TS position within the CRD continuous registration period but do not have a passing grade of the Series 7 (S7) Exam. In these instances, the Manual Review Method will afford each state regulator with the ability to verify and determine whether the individual qualifies.

Professional Designations and IA Representative (RA) Registration

Many states participating in the electronic registration of IA representatives (RAs) will allow those that hold one or more of five professional designations to serve as a basis for waiving the exam requirement or as an alternate qualification. The Web CRD System will verify whether an investment adviser representative holds a valid professional designation when a Form U-4 Filing is submitted if the system has been updated with the individual's information by the designating authority. The IA representative (RA) may request to qualify with one of the five professional designation boxes checked in Section 8, "Professional Designations," of the U-4 Filing:

CFP - Certified Financial Planner
- Awarded by the Certified Financial Planner Board of Standards, Inc.
ChFC - Chartered Financial Consultant
- Awarded by the American College, Bryn Mawr, Pennsylvania
PFS - Personal Financial Specialist
- Awarded by the American Institute of Certified Public Accountants
CFA - Chartered Financial Analyst
- Awarded by the Association for Investment Management Research
CIC - Chartered Investment Counselor
- Awarded by the Investment Counsel Association of America, Inc.

Individuals who hold any of these valid designations can check the boxes on a U-4 Filing to request to qualify as an IA representative (RA) if the information has been provided to Web CRD by the designating authority. Through a direct feed of data from the designating authorities, Web CRD will be uploaded with the identifying information of individuals that hold valid professional designations. Please note that the frequency of updates received from the designating authorities will vary (i.e. weekly, bi-weekly, or monthly). If a firm attempts to qualify an individual with a professional designation before Web CRD has received the data feed from the designating authority, a system Completeness Check will prevent the filing from being submitted because the designation could not be verified. The firm will receive this message: "You have made an invalid Designation request."

Best Practice: The firm should contact the designating authority to request that the individual's information be updated on Web CRD. Firms will need to supply the designating authority either the individual's CRD Number (which is assigned with the Initial Filing is started) or Social Security Number. After a reasonable amount of time, the firm can verify that the information is now contained in CRD by re-running the Completeness Check for the filing.

The process for firms with individuals that hold either the PFS designation with the AICPA and/or CFA designation with AIMR is that they first contact the respective designating authority to have their individuals' information forwarded to Web CRD. If the applicant holds more than one designation besides the PFS and/or CFA designations and checks all of them on the U-4 before contacting the designating authority (AICPA or AIMR), the firm will receive a Completeness Check error ("You have made an invalid Designation request"). The applicant can still use the professional designation to qualify by:
- Unchecking the PFS and/or CFA Designation boxes, but still checking the other appropriate designation(s) he/she holds
- The U-4 should now pass the Completeness Check

CAUTION: Firms should be aware that if they "uncheck" all of the Professional Designation boxes in order to pass the Completeness Check and submit the filing:

The qualifying exam(s) will be required.
The applicant will be 'Exam Deficient' until the qualifying exam(s) are scheduled and passed.

Therefore, it is recommended that firms hold the filing as "Pending" in their Pending Queue until the designating authority has supplied the information to Web CRD.

Contact Information for the Designating Authorities

Designating Authority Designation Granted Contact Telephone # Email

American College (Bryn Mawr, PA) Chartered Financial Consultant (ChFC) Not Available 888-AMERCOL (263-7265) Not Available

American Institute of Certified Public Accountants (NY/NJ) Personal Financial Specialist (PFS) Andrew Gioseffi 212-596-6020 agioseffi@aicpa.org

Association for Investment Management Research (VA) Chartered Financial Analyst (CFA) Not available 800-247-8132 Not available

Certified Financial Planner Board of Standards (VA) Certified Financial Planner (CFP) www.cfp.net 800-433-4292 Not available

Investment Counsel Association of America (DC) Chartered Investment Counselor (CIC) Andrea Owens 202-293-4222 andrea.owens@icaa.org

Please note that the process for the AICPA (PFS Designation) and AIMR (CFA Designation) is for the firms to first contact the designating authority (AICPA and/or AIMR) to have these designating authorities forward the individuals' information to Web CRD. For additional information regarding the CFA professional designation, please visit the AIMR Web Site at: www.aimr.org/pdf/adv_waiver.pdf. Individuals holding the PFS and/or CFA professional designations who would like to use it to request to qualify as an IA representative (RA) should:

Contact the AICPA and/or AIMR with the individual's CRD# or SSN#.
AICPA and/or AIMR checks for eligibility and sends a data file to NASD. (NASD uploads the data to the system.)
The filing will pass the Completeness Check and the Form U-4 can be submitted with the PFS or CFA Designation box checked:
- No exam is scheduled
- No exam fee is charged

If the firm unchecks all of the Professional Designation boxes in order to submit the filing, then the IA representative's (RA) registration request will be 'Exam Deficient' and the firm will have to:

Fax a valid Professional Designation certificate to the State
Wait until the state overrides the deficiency and approves the individual

Special note to currently registered investment adviser representatives that transition on to Web CRD: Professional designations will not show on individuals' CRD records or on any CRD reports until either a U-4 (with a Professional Designation box checked) is successfully submitted for the individual or until a U-4 Amendment (with a Professional Designation box checked) is subsequently filed after the information has been uploaded to the system. The information will then be viewable under View Individual in the individual's composite record.

Dual Registration

Some jurisdictions prohibit "dual registration" which occurs when an individual chooses to maintain a concurrent registration as a representative with two or more firms (either IA and/or B/D). Jurisdictions that prohibit dual registration would not, for example, permit an investment adviser representative (RA) working with Firm A to maintain a registration with Firm B. Before seeking a dual registration status, you should consult the applicable rules or statutes of the jurisdictions with which you seek registration. If you are seeking "dual registration," you must answer "yes" to either 3A or 3B in the Registration with Unaffiliated Firms section of the U-4 Filing.

In certain circumstances, states that won't normally allow dual registration will allow it if the firms are affiliated. The system will not recognize firms as "affiliated" unless the filing firm reports the affiliated firm under Question 10 A or 10B on the Form BD or Item 7A(3) on the Form ADV.

The table below contains the registration combinations and "dual" selections each state has when legislating its dual registration statutes. A state could have a different mandate for every registration combination (RR/RR, RA/RA, RR/RA). Additionally, the policies regarding "dual registration" will vary from state to state. It is recommended that you check with the jurisdiction with which you are seeking registration for additional clarification.

DUAL CONDITION ALLOWS DUAL REGISTRATION

RR/RR Always Never Affiliates Only

RR/RR Always Never Affiliates Only

RR/RR Always Never Affiliates Only

Changes to the Uniform Forms

Concurrently, with the implementation of Release 4.0 and the electronic registration of investment adviser representatives, revised versions (03/2002) of the Forms U-4 and U-5 are also being implemented. The revised forms became effective March 18, 2002. Copies of the new electronic forms are available on NASD Regulation's Web Site. The revised forms include technical amendments that do not require member firms to "re-file" disclosure or administrative information for their associated persons.

NASD Regulation and a "Project Group" (comprised of the North American Securities Administrators Association [NASAA], the states, industry representatives, investment adviser community representatives and other SROs) revised the forms in order to:

Accommodate the electronic submission of investment adviser representative filings
Establish procedures that enable broker/dealer firms and investment adviser firms employing dually registered persons (i.e., persons who are employed by more than one unaffiliated broker/dealer or investment adviser firm) to concur with and adopt information contained in Forms filed on such persons
Clarify the filing instructions
Provide separate paper filing instructions for certain investment adviser representative filers and other state-only filers that do not use the CRD or IARD systems
Clarify certain items that have been confusing to Web CRD users
Make certain formatting and technical changes to the forms that complete the transition from a paper-based filing model to an electronic-filing model
Update the Form U-4 to add examination and registration categories not previously included

In an effort to align the U-4 and U-5 with their electronic counterparts, the "look and feel" of the forms has changed. The printed forms are virtually identical in appearance to the screens that are presented in Web CRD.

Highlights of the Uniform Form Changes

Form U-4

Section Headers Replace Numbered Fields
The revised Forms U-4 and U-5 eliminate the numbered fields used in previous versions because the electronic interactive filing format used in the Web CRD and IARD systems present information in a specified order, and effectively eliminates the need for individually numbered data fields. Instead, the revised Forms U-4 and U-5 contain 15 and 8, respectively, "section headers" that are numbered and clearly describe the types of information elicited or action required by the applicant or firm, with applicable subquestions contained within each section. Organizing the current fields into sections has changed the question numbers, but there are no substantive changes to the questions. Of note, Question 14 on Form U-4 replaces Question 23 as the "Disclosure Question," and contains sub-questions numbered 14A, 14B, etc.
Explanation of Terms and Specific Instructions
Consistent with the purposes stated above, the revised Explanation of Terms and Specific Instructions sections have been simplified and generally revised to include instructive language. The Explanation of Terms section includes seven new terms and an alphabetical list of definitions to better aid applicants and firms.ⁱ In addition, the Specific Instructions include directions for investment adviser representative-only applicants (i.e., those individuals not also registered or seeking registration with a broker/dealer), as well as separate instructions for paper filers.
Private Residence Check Box
The new General Information section contains a "private residence check box" that allows individuals to indicate that their office of employment address is a private residence. This feature was added to address privacy concerns raised by the investment adviser community in connection with the potential release to the public through open records laws or other programs of home addresses of investment advisers who are sole practitioners operating out of their homes and to notify regulators that the address is a private residence.
Fingerprint Information
On the revised Form U-4 is a new "Fingerprint Information" section that replaces Question 8a on the 1999 Form U-4, and addresses procedures for submitting fingerprints to register with SROs and states. This section includes a representation affirming that an electronic filer who seeks registration with a broker/dealer is submitting or will promptly submit fingerprint cards consistent with SRO rules. The revised Form U-4 modifies the representation regarding fingerprint exempt firms to permit an applicant firm to represent that the subject of a filing is exempt from the fingerprint requirement if the applicant meets one or more of the exemptions established by Rule 17f-2 under the Securities Exchange Act (Exchange Act). In addition, this section also addresses the applicable scenarios for the filing of fingerprint cards by individuals who are filing only as investment adviser representatives, and who may not be required to submit fingerprint cards for one or more jurisdictions.
Dual Registration/Affiliated Firms
Because the meaning of "dual registration" in Questions 9 and 10 on the 1999 Forms U-4 and U-5 has caused some confusion for both regulators and member firms, the revised Forms replace former Questions 9 and 10 with the "Registration with Unaffiliated Firms" and "Registration with Affiliated Firms" sections, respectively. The "Registration with Unaffiliated Firms" section states the majority view within the states, that is, those individuals who answer this question affirmatively will be considered to be "dually registered." Individuals/firms are instructed to consult applicable state or SRO rules to determine whether dual registrations are permitted. The "Registration with Affiliated Firms" section applies only to individuals registering with firms that are under common ownership or control.
Registration Categories
The revised Forms U-4 and U-5 include changes to the registration categories to accommodate the addition of the International Securities Exchange (ISE) as a new SRO, and the new Private Placement (PR) position required by the Gramm-Leach-Bliley Act.ⁱⁱ
Professional Designations Section
The revised Form U-4 adds Section 8, "Professional Designations," to enable an individual requesting registration as an RA to seek a waiver from examinations or serve as an alternate qualification if he or she currently maintains certain designations (i.e., Certified Financial Planner, Chartered Financial Consultant, Personal Financial Specialist, Chartered Financial Analyst or Chartered Investment Counselor).
Note: Firms with individuals that hold the Personal Financial Specialist (PFS) designation with the AICPA and/or the Chartered Financial Analyst (CFA) designation with AIMR must contact the respective designating authority in order to have their information forwarded to Web CRD if they wish to request to qualify as an IA representative (RA registration) with one of these professional designations. For additional information regarding the CFA professional designation, please visit the AIMR Web Site at www.aimr.org/pdf/adv_waiver.pdf
Signature and Acknowledgment Sections
New Section 15 on Form U-4 enables individuals and appropriate signatories to go directly to designated signature fields to execute the electronic signatures required by the forms. Sections 15A and 15B address the individual/applicant's acknowledgment and consent and the firm/appropriate signatory's representations, both of which must be completed on all Initial or Temporary Registration Form Filings. Section 15C addresses the Temporary Registration Acknowledgment, which must be completed for all temporary registrations. Section 15D has been added to address an individual/applicant's acknowledgment and consent to amendments to the disclosure questions or the Disclosure Reporting Pages (DRPs). Firms and appropriate signatories must complete Section 15E for all Amendment Form Filings.
In addition, Section 15F, "Firm/Appropriate Signatory Concurrence," enables one firm to "concur" with, and thereby adopt as its own, a filing made by another firm with which an individual is also registered (i.e., an individual registered with more than one broker/dealer and/or investment adviser firm). The Concurrence Filing essentially provides firms with a faster, more efficient method of fulfilling their reporting obligations on an associated person who also is associated with another entity.
Concurrence Filing Procedures
With the implementation of the electronic filing for investment adviser representatives, investment advisers will be able to electronically submit the Forms U-4 and U-5 to register and terminate the registrations of their IA representative (RAs) with appropriate state regulators. Individuals who are registered with both a registered investment adviser firm and a broker/dealer will share a single registration record on the CRD System. As discussed above, the changes to Form U-4 allow a member broker/dealer to concur with a filing submitted by any firm, including an investment adviser, that employs a registered person who is also registered with that member broker/dealer. Enabling member broker/dealers to concur with filings submitted by an investment adviser, and vice versa, regarding a particular person will streamline the registration process and make it more efficient for members to comply with their reporting obligations on an associated person who also is associated with another entity.
To implement this new process, the CRD System will automatically notify a member firm of the submission of a Form U-4 or Amendment for one of its associated persons by another broker/dealer or an investment adviser that also employs that individual. The firm that is notified will then be able to review the information that has been submitted and execute a "Concurrence Filing," which communicates to the CRD System (and, therefore, all appropriate regulators) that it has adopted the filing as its own.ⁱⁱⁱ
In the event that multiple firms associated with any particular individual submit different DRPs on the same disclosure event, NASD Regulation staff will "flag" the affected record on the CRD System to put regulators and the involved firms on notice that differences between the two filings exist. The "Material Difference Flag" will be set whenever there is a difference between the information provided in any of the fields eliciting objective factual information (i.e., any of the DRP fields, with the exception of the last field on the DRP, which is reserved for the registered representative's summary or commentary on the event).^iv

Form U-5

Section 8 of the revised Form U-5 addresses the signature requirements on that Form including the firm acknowledgment in Section 8A and a new individual acknowledgment and consent in Section 8B. Although only appropriate signatories of firms are required to sign Form U-5, in the ordinary course of business, individuals who are the subject of Form U-5 may be required to submit signatures under two scenarios:

Formerly registered individuals are obligated to submit to the CRD system address changes for two years following the termination of their registration under NASD rules;^v and
Registered or formerly registered individuals have the opportunity to file an Internal Review DRP-Part II to respond to a report on a Form U-5 by that individual's previous employer that the individual is subject to an internal review. New Section 8B enables individuals submitting an address change or Internal Review DRP-Part II to attest that the information is accurate and complete.

New Section 8B enables individuals submitting an address change or Internal Review DRP-Part II to attest that the information is accurate and complete.

In connection with the revised Forms U-4 and U-5, NASD Regulation has created a Uniform Forms Reference Guide to provide member firms and other users of the Forms with contact and other explanatory information. The Guide is not part of the Forms, but is available on the NASD Regulation Web Site.

As a result of the implementation of Release 4.0 and the new versions of the Forms U-4 and U-5, there are important system impacts of which you should be aware:

All "Pending" Filings that were still in your "Pending Queue" as 8 p.m., Eastern Time, Friday, March 15, became read-only with the implementation of the new form versions and the changes to the forms. It is important that you review the contents of that queue and complete and submit those forms that you do not wish to re-key.
Redlining is not visible for the first filing of the new form versions submitted for each individual in CRD. This is because the changes made on the March 2002 revised forms make it impossible to do a one-to-one comparison with the previous form version(s) (8-99) for redlining purposes. However, with each subsequent filing of the revised (March 2002) forms, redlining will occur and you can view the changes in "Redline Mode" in View Historical Filings. (System Note: Redlining will only be viewable if the previous filing was submitted by the same firm and is the same filing type. An enhancement will be implemented with the next CRD Release that will display Redlining on filings of the same type made by any firm.)
The version date of 03/2002 to the Forms U-4 and U-5 has been added on the system for viewing purposes.
Links have been added to "Specific Instructions and Explanations of Terms" for all blank form types.

ⁱ The revised forms now define the following terms: affiliated, applicant, designated entity, filing firm, firm, firm CRD Number, and individual CRD Number.

ⁱⁱ The PR position was implemented in May 2001 as required by the Gramm-Leach-Bliley Act of 1999, which added a new subsection (j) to Section 15A of the Exchange Act and created a new NASD registration category for individuals engaged only in private securities offerings. See Section 203, P.L. 102, Gramm-Leach-Bliley Act (Nov. 12, 1999).

ⁱⁱⁱ See generally Article V, Section 4 of the NASD By-Laws, Forms U-4 and U-5.

^iv Firms will receive notice filings for all Form U-4 filings that affect their associated persons who are also registered with another broker/dealer or investment adviser. Such firms would not be required to make concurrence filings where the Form U-4 amends information that is relevant only to the broker/dealer or investment adviser that initially filed the Form U-4 (e.g., such firms will not have to submit concurrence filings for changes to registrations, office of employment address, etc. that are specific to the entity making the initial filing).

^v When a difference is flagged, NASD Regulation staff will alert the firms involved to request that they resolve the difference. If the firms are not able to reach an agreement within 30 calendar days, NASD Regulation staff will refer the matter to a state regulatory and/or NASD Regulations’ Member Regulation or Enforcement staff, as appropriate, based on the facts and circumstances of the situation, for review and resolution.

Completeness Checks

Form U-4 Completeness Checks

Web CRD automatically performs a Completeness Check before a filing is submitted in order to prevent firms from submitting an incomplete filing. A firm can also perform a Completeness Check at any time on its own, prior to submission, to check the filing for completeness of the required fields. The Completeness Check message provides the error location and a description of the error. The user can hyperlink from the error location and complete the necessary fields until the errors have been corrected.

The Completeness Checks for Web CRD are slightly different with Release 4.0.

As a part of this Release, the NRF Completeness Checks have been relaxed to no longer require the inputting of personal data for an individual when 'Termination' is checked. Firms no longer have to enter the personal information required for the individual in order to terminate "back office" individuals who were associated with the firm and were converted to Web CRD from the Legacy CRD System. Therefore, firms are now able to complete NRF terminations themselves, and do not need to contact the Call Center to have NASDR run a "data script" order to complete the termination.

General Completeness Checks

All form questions that require a "Yes" or "No" response shall be answered.
The system shall require the following fields to be completed:
- Employment date
- Office of Employment Street Address (input at least one address)
- City
- State/Country
- Postal Code
The system shall display an error message if the U-4 Employment Date is greater than the system date.
The system shall require a zip code to be entered for all addresses if a state is entered.
The system shall not require a state to be entered if a country is selected.
The system shall allow the U-4 to be submitted without the Temporary Registration Acknowledgment Page being signed.
The system shall not perform any completeness checks on the Concurrence Filing except for the Concurrence Signature page.

Fingerprint Information Completeness Checks

The user must select one of the fingerprint options.
A barcode number cannot be submitted twice.
The IA representative fingerprint option cannot be selected if an RR registration exists or is requested with any firm on the filing.
The system shall display an error message if any one of the RR fingerprint options is selected and no RR registration exists or is being requested for any firm on the filing.

Unaffiliated Firms Completeness Checks

On an Amended U-4 Filing, questions 3A and 3B shall both be required.
On a Dual U-4 Filing, questions 3A and 3B shall both be required.
On any Relicensing U-4 Filing, questions 3A and 3B shall both be required.
On a Dual U-4 Filing, either question 3A or question 3B shall be answered Yes.

SRO/Jurisdiction Registrations Completeness Checks

At least one SRO/Jurisdiction must be checked.
If an RA position is being requested, the firm must hold an active IA registration status with that regulator.
The system shall display an error message if any of the following apply:
- the individual's status is CE2YEARTERMED;
- the filing type is one of the following: Amendment, Dual, Relicense All, Relicense CRD, Relicense IA;
- the individual holds an approved RR registration.
- RR registrations are being requested on the filing.
RA positions cannot be requested with the following states: Georgia (GA), Louisiana (LA), New York (NY), Michigan (MI), Minnesota (MN), Ohio (OH), South Carolina (SC), Tennessee (TN), Wyoming (WY).

Affiliated Firms Completeness Checks

The system shall display an error message if the user is attempting to add an affiliated firm and the individual currently has an active firm association on the system with that firm.
The system shall require at least one registration be requested for an affiliated firm being added.
The system shall display an error message if an affiliated firm is entered on Form U-4 and the affiliated firm is not found to be a bank affiliate, business affiliate or advisory affiliate of the filing firm.

Exam Requests Completeness Checks

The user must provide the date if an exam type is selected.
If the S14 is selected, the CO must be requested.
The same completeness checks run for the S14 as for NASD exams.
NASD exams can only be requested if:
- the individual has this exam deficiency
- the individual has a re-qualification by exam deficiency

Professional Designations Completeness Checks

The system shall verify the designations that have been selected by
1. matching the Social Security number on the U-4 with the Social Security Number for the designation; or
2. If no match found for Social Security Number, by matching the CRD# and the last name on the U-4 to the CRD# and last name for all designation records that do not contain a Social Security Number.
The system shall display an error message if a designation is selected and no RA positions are currently held or being requested.

Identifying Info/Name Change Completeness Checks

The following fields on the Personal Information page shall be required:
- First Name
- Last Name
- Date of Birth
- Height (ft)
- Height (in)
- Weight (lbs)
- Sex
- Hair Color
- Eye Color

Residential History Completeness Checks

The system shall generate an error message if one residential address does not have a "To" date that is equal to PRESENT.
There cannot be a break of more than three months between Residential History records.
The system shall require information regarding the applicant's last five years of residential history.
The following fields must be completed: From, To, Street Address 1, City, and State/Country.

Employment History Completeness Checks

There cannot be a break of more than 3 months between Employment History records.
The system shall require information regarding the applicant's last 10 years of employment.
The system shall generate an error message if the following fields are not completed: From, To, Name, City, State/Country, Investment Related Business, and Position Held.

Initial/Dual Signature Page Completeness Checks

If the filing type is Initial, the user must complete the signature and date fields in both the 15A-Individual/Applicant's Acknowledgment and Consent Section and 15B-Firm/Appropriate Signatory Representations Section.
If the filing type is Dual, the user must complete both 15A. Individual/Applicant's Acknowledgment and Consent Section and 15B. Firm/Appropriate Signatory Representations Section.

Concurrence/Page 2 Signature Completeness Checks

If the filing type is Initial, the user must complete the signature and date fields in both the 15A-Individual/Applicant's Acknowledgment and Consent Section and 15B-Firm/Appropriate Signatory Representations Section.
If the filing type is Dual, the user must complete both 15A- Individual/Applicant's Acknowledgment and Consent Section and 15B- Firm/Appropriate Signatory Representations Section.

Relicense Signature Page Completeness Checks

The signature and date fields in both the Applicant Signature and the Appropriate Signatory must be completed.
The system shall display a warning message if 15C - Temporary Registration Acknowledgment is not signed as part of any Relicense filing.

Amendment Signature Page Completeness Checks

If the filing type is Amendment with disclosure changes, the user must complete the signature and date fields in 15D- Individual/Applicant's Amendment Acknowledgment and Consent Section.
If the filing type is Amendment, the user must complete the signature and date fields in the 15E- Firm/Appropriate Signatory Amendment Representations Section.

General DRP Completeness Checks

If any of the Disclosure Questions in a disclosure category are answered "Yes," then the appropriate Disclosure Reporting Page shall be included in the filing.

Form U-5 Completeness Checks

General Completeness Checks

If the data for the individual has been updated since the filing was created, the system shall present the user with an error message explaining that no other Completeness Checks shall be performed.
For a Partial Form U-5, the system shall require that there be one request for withdrawal from at least one firm including affiliated firms.
The system shall require a Postal Code entry in the Address Field, if a State entry is present.
The system shall require that the CRD Branch# entered be valid for that firm.

Current Residential Address Completeness Checks

The system shall require that the "From" date be entered in MM/YYYY format.
The system shall require an entry of a Current Address unless the Reason for Termination is deceased.
The system shall require an entry in the following fields: From, Street Address, City, State and Postal Zip if a State entry is present.
The system shall require an entry in the following fields: From, Street Address, City and Country if no State entry is present.

Full Terminations Completeness Checks

When filing a Full U-5 termination, the system shall require an entry in the Explanation of Termination text box when the Reason for Termination dropdown list selection is: Permitted to Resign, Discharged, or Other.
When filing a Full U-5 termination, the system shall require a selection, other than Blank, in the Reason for Termination drop down list.

Date of Termination Completeness Checks

For Full or Partial U-5 Termination, the system shall require that a date be entered for the Date Terminated.
The Date Terminated shall be less than or equal to the current date unless the current date is between 11/1 and 12/31 of the current year.
If the current date is between 11/1 and 12/31 of the current year, the system shall allow the user to enter a future date of 12/31 of the current year in the Date Terminated text box.
The Date Terminated must be equal to or greater than the employment start date with the firm association.

Affiliated Firms Terminations List Completeness Check

For a Full U-5, if the Multiple Terminations radio button is "Yes," at least 1 affiliated firm must be selected for Full termination.
For a Full U-5, if the Multiple Terminations radio button is "No," no affiliated firms may be selected for Full termination.
For a Partial U-5, if the Multiple Terminations radio button is "Yes," at least 1 affiliated firm must request at least 1 registration withdrawal.
For a Partial U-5 termination, if the Multiple Terminations radio button is "No," no affiliated firms may request registration withdrawals.

Disclosure Questions Completeness Checks

If any of the disclosure questions A-E were answered with a "Yes," the system shall require that the question's corresponding Disclosure Reporting Page (DRP) be filed.
The system shall require that all disclosure questions be answered "Yes" or "No."

SRO Partial Terminations - General Completeness Checks

The system shall require that all disclosure questions be answered "Yes" or "No."
If any of the disclosure questions A-E were are answered with a "Yes," the system shall require that the question's corresponding disclosure reporting page be filed.

SRO Partial Terminations: NASD - Completeness Checks

Continues to Have Must remain approved

NASD GP NASD GS, CS, IE, CN, CD, or JP

NASD IP NASD IR, GS, IE, CN, or CD

NASD MP NASD MR or GS

NASD SU NASD GS or (IE & MR) or (CN & MR) or (IR & DR & OR & CS & MR & RG) or (CD & MR)

NASD DP NASD DR, GS, IE, CN, or CD

NASD OR NASD CS, RG, or GS

NASD PG NASD RG, GS, IE, CN, or CD

SRO/PARTIAL Terminations-NYSE/CSE Completeness Checks

Continues to Have Must remain approved

NYSE BM NYSE GS, IE, CN, or CD

CSE GP CSE GS or CS

CSE IP CSE IR or GS

CSE MP CSE MR or GS

CSE DP CSE DR, GS, IE, CN, or CD

SRO/Partial Terminations - Chicago Stock Exchange

Continues to Have Must remain approved

CHX GP CHX GS or CS

CHX MP CHX MR or GS

CHX DP CHX DR, GS, IE, CN, or CD

CHX OR CHX CS, RG, or GS

Jurisdiction Partial Terminations Completeness Checks

If there is at least one state or jurisdiction RR registration not requested for withdrawal, the system shall require that at least one NASD registration not be requested for withdrawal.

Signature Page Completeness Checks

The system shall require that the following fields be completed on the Signature Page:
- Person to contact for further information
- Telephone # of person to contact
- Signature of Appropriate Signatory
- Date (MM/DD/YYYY).

Form U-4 Filing Types Expanded With Release 4.0

There are now nine Form U-4 Filing Types with Release 4.0. There is a new "Concurrence Filing" that has been added (see the article in this Bulletin for detailed information regarding it). Also, there are now three Relicensing Filing Types to accommodate "Relicensing" by registration categories and include investment adviser representatives: Relicense All Registrations, Relicense Only IA Registrations, and Relicense Only CRD Registrations. Please familiarize yourself with each. It is important that when submitting a Form U-4 Filing, you select the correct type in order to receive the desired type of registration.

Initial or transfer registered more than 30 days ago:

Choose this type if the applicant has never been registered on CRD or was last registered more than 30 days ago with a previous firm. By initiating a form filing on behalf of the individual selected, you acknowledge that you have the consent of that individual to submit the selected form filing, or that you are considering this person for employment and have obtained and will keep on file this person's written consent to review his/her CRD record for that purpose.

Amendment:

Use an amendment to add or change information on an individual already registered with your firm.

Concurrence:

Select this filing type to allow you to submit a Form U-4 Amendment Filing concurring to and thereby adopting Form U-4 changes made by another firm that employs the individual. A Concurrence Filing can be filed when any of the following information was changed on a Form U-4 filing submitted by the other employing firm and you are concurring to those changes:

Identifying Information/Name Change
Other Names
Residential History
Employment History
Other Business
Disclosure Questions
Disclosure Reporting Pages (DRPs)

Page 2 Amendment for BD Schedule A/B:

Use the Page 2 Amendment to add or change personal, employment or residential information on Direct or Indirect Owners of the firm that are not required to submit a full Form U-4.

Page 2 for BD Schedule A/B:

Use the Page 2 for BD Schedule A/B for individuals that appear on Schedule A or B of the Form BD. It provides personal, employment and residential information on Direct or Indirect Owners of the firm who are not required to submit a full Form U-4.

Dual Registration:

Choose this type if the applicant intends to maintain registrations with 2 or more unaffiliated investment adviser firms and/or broker/dealer firms. By selecting this filing type, you are choosing to answer "yes" to Question 3A or 3B on the Form U-4. If you do not wish to answer "yes" to Question 3A or 3B, you must select a different filing type, i.e., either Initial or Relicense. By initiating a form filing on behalf of the individual selected, you hereby acknowledge that you have the consent of that individual to submit the selected form filing, or that you are considering this person for employment and have obtained and will keep on file this person's written consent to review his/her CRD record for that purpose.

Relicense All Registrations or transfer within 30 Days:

Choose this type if the applicant wishes to register with your firm within 30 days from the date of termination with ALL previous firms with which he/she has been working, and intends to be SOLELY with your firm. By selecting this filing type, you are choosing to answer "no" to Questions 3A and 3B on the Form U-4 and to relicense all registrations. The system will start tracking for a Form U-5 Filing to terminate all current positions for the individual. If you do not wish to answer "no" to Questions 3A and 3B or to terminate all current positions, you must select a different filing type, i.e., either Initial or Dual Registration. By initiating a form filing on behalf of the individual selected, you acknowledge that you have the consent of that individual to submit the selected form filing, or that you are considering this person for employment and have obtained and will keep on file this person's written consent to review his/her CRD record for that purpose.

Relicense Only CRD Registrations or transfer within 30 Days:

Choose this type if the applicant wishes to register as a Broker/Dealer Agent (AG) with a new firm and wishes to terminate his/her AG positions with any other firms, but leave any Investment Adviser associations he or she may have current. By selecting this filing type, you are choosing to answer "no" to Questions 3A and 3B on the Form U-4 and to relicense only CRD registrations. The system will start tracking for a Form U-5 Filing to terminate all current positions for the individual. If you do not wish to answer "no" to Questions 3A and 3B or to terminate all current positions, you must select a different filing type, i.e., either Initial or Dual Registration. By initiating a form filing on behalf of the individual selected, you acknowledge that you have the consent of that individual to submit the selected form filing, or that you are considering this person for employment and have obtained and will keep on file this person's written consent to review his/her CRD record for that purpose.

Relicense Only IA Registrations or transfer within 30 Days:

Choose this type if the applicant wishes to register as an investment adviser representative (RA) with a new firm and wishes to terminate his/her RA positions with any other firms, bur leave any Broker/Dealer associations he/she may have current. By selecting this filing type, you are choosing to answer "no" to Questions 3A and 3B on the Form U-4 and to relicense only RA registrations. The system will start tracking for a Form U-5 Filing to terminate all current positions for the individual. If you do not wish to answer "no" to Questions 3A and 3B or to terminate all current positions, you must select a different filing type, i.e., either Initial or Dual Registration. By initiating a form filing on behalf of the individual selected, you acknowledge that you have the consent of that individual to submit the selected form filing, or that you are considering this person for employment and have obtained and will keep on file this person's written consent to review his/her CRD record for that purpose.

Introducing a New Filing Type: The Concurrence Filing

In conjunction with the electronic registration of investment adviser representatives, Release 4.0 implemented a new filing type in Web CRD, the Concurrence Filing. A Concurrence Filing allows a firm to concur with and adopt information submitted by another firm on an individual who is also registered with the filing firm. As background, Article V, Section 2 (c) of the NASD By-Laws requires registered individuals to keep the Form U-4 current at all times. Therefore, when a dually registered individual, i.e., an individual employed by more than one unaffiliated broker/dealer and/or investment adviser, submits a U-4 filing with one firm, the other firm will have the opportunity to complete a Concurrence Filing to agree to and adopt the information submitted. This new filing type satisfies the dually registered individual's obligation to keep his/her Form U-4 current with each firm. It facilitates "concurrence" with a U-4 filing made by another firm (IA or BD) on behalf of an individual that is also registered with that other firm.

The Concurrence Filing consists of a "read only" Form U-4, meaning no data can be changed. Only 15F (Firm/Appropriate Signatory Concurrence) of the 'Signatures' section can be completed. It can be filed when any of the following information has been changed on a Form U-4 filing submitted by the other employing firm, thus concurring to and adopting the change(s):

Personal Information, i.e., hair color, eye color, etc./Name Change
Other Names
Residential History
Employment History
Other Business
Disclosure Questions
Disclosure Reporting Pages (DRPs)

For example, if Firm A submits a U-4 filing with a change of address or updated disclosure information, Firm B (required to submit the same filing obligations) can agree to and adopt the changes and/or updates by submitting a Concurrence Filing.

It is only necessary to concur with or acknowledge "shared" information, i.e., information specific to the individual regardless of the firm with which he or she is employed is with. It does not apply to information that is specific to just one firm, e.g., registration and exam requests, office of employment address, CRD Billing Code, branch office assignment.

The Concurrence Filing Notification Process:

The individual's Composite Screen is updated to reflect "Registered with Multiple Firms".
Web CRD notifies the firm, via the Other Firm U-4 Notice Queue, of the submission of a Form U-4 for one of its registered persons by another broker/dealer or investment adviser.
2 (a). Firms can also set up receipt of a new e-mail Firm Notification that will notify a pre-determined individual at the firm when a registered individual enters the 'Other Firm U-4 Notice Queue.' Instructions for initiating the receipt of any or all of the Firm Notifications can be found in this Bulletin.
A firm can view the U-4 filing submitted by the "other" firm.

How To Submit A Concurrence Filing:

Step 1: Access CONCURRENCE FILING from the:

Site Map > Concurrence hyperlink
or
Forms Tab on Tool Bar [U-4 Form>Concurrence]
or
Other Form U-4 Filing Notice Queue
- Note: If you access the Concurrence Filing via this Queue, go directly to Step 5.

Step 2: Perform an INDIVIDUAL SEARCH.

Step 3: Click on the NAME hyperlink.

Step 4: Click EACH SECTION of the U-4 filing from the Navigation Bar or Footer in order to review the information on the filing.

Step 5: Click SIGNATURE from the Navigation Bar or Footer.

Step 6: Type the DATE (mm/dd/yyyy) and SIGNATURE OF APPROPRIATE SIGNATORY in the 15F: Firm/Appropriate Signatory Concurrence fields.

Step 7: SUBMIT the Concurrence Filing

Before submitting a Concurrence Filing, review the information filed by the other firm the individual is dually registered with to make sure your firm agrees that the information was correctly reported. Also check the individual's Composite Screen in View Individual and/or your Outstanding Disclosure Letters Queue to see if the individual's record has been flagged for submitting different U-4 DRPs to report the same event (i.e., Material Difference Flag set to 'Yes'), since a Concurrence Filing will also resolve any outstanding material differences.

The submission of the Concurrence Filing type is optional. If the firm does not agree with the submitted information and does not wish to concur with the new data, it can submit a U-4 Amendment.

The Material Difference Flag

The new Material Difference Flag in Web CRD relates directly to disclosure and applies to individuals who are registered with more than one unaffiliated broker/dealer and/or investment adviser firm (e.g., BD/BD, BD/IA or IA/IA). It indicates a difference exists in U-4 Disclosure Reporting Page (DRP) details for the same disclosure event. In the event that multiple firms associated with any particular individual submit DRPs reporting different information about the same disclosure event [the difference of one word will set the flag], the CRD/PD Disclosure Review staff, during their manual review process, will flag the affected record on the CRD System. This will identify on the system that a disclosure difference exists and will immediately put regulators and involved firms on notice that a difference exists. The only exception is when a U-4 Amendment is submitted to update the status of a previously reported disclosure event. As an example, when a U-4 Amendment is submitted to report that a previously pending action has now been resolved, it will not trigger the Material Difference Flag as the individual is required to timely report the final disposition. Additionally, the Representative Comment/Summary field (the last field on each DRP type) is excluded from the Material Difference review as the field includes the representative's summary or comments regarding the disclosure event as a supplement to the factual DRP fields.

The Material Difference Flag was developed for two main reasons:

With Release 4.0 and the deployment of the investment adviser representative (RA) electronic registration functionality, there is an increased population of dually registered individuals in the system.
Dually registered individuals will now encompass individuals who are registered with multiple broker/dealers (BD), multiple investment advisers (IA), or a BD and an IA.

The Review Process

The CRD/PD Disclosure Review (DR) staff as part of the manual review process manually sets the Material Difference Flag. All firms with whom the individual is registered are notified by the DR staff, via an "Inquiry" or a "Deficiency" letter (whichever is appropriate):

A Deficiency Letter will be sent when the individual's registration requests are "pending" or "deficient".
An Inquiry Letter will be sent when the individual's registrations are already approved.

The letters will advise the firms of the material difference, identify the occurrence(s) for which the flag was set, and request that the firms work to resolve the disclosure difference in a timely manner. Firms will receive notice and can review the details of the letters in their Outstanding Disclosure Letters Queue. Depending on when the filing that triggered the material difference in disclosure is reviewed, the firm may become aware of the U-4 Filing via the Other Firm U-4 Filing Queue prior to receiving the disclosure letter. The CRD System will send a notice to all the firms with whom the individual is associated via the Other Firm U-4 Filing Queue whenever a U-4 is submitted on behalf of the individual by another firm with whom the individual is also employed. Firms may also elect to receive an e-mail notification, which provides notice to a specified individual at the firm, whenever a registered individual enters the firm's Other Firm U-4 Filing Queue. [See the instructions for setting up receipt of e-mail Firm Notifications in this Bulletin.]

Regulator's Role

Regulators (e.g., jurisdictions and SROs with whom the individual is registered or has requested registration) will also receive notice that the Material Difference Flag has been set for one or more disclosure occurrences. The Material Difference Flag is a trigger for regulators to review the individual's disclosure record to see if the representative omitted a material fact or otherwise submitted a false or misleading filing. "Pending" registration requests will not be approved until the discrepancy is resolved. Regulators will track Material Difference Flag discrepancies with resolution expected within 30 days.

Firm's Responsibility

Firms are obligated to review the DRPs in question, identify the differences in the DRP details that triggered the flag, and contact the individual and/or other firms(s) to determine the basis for the new DRP and how the disclosure difference will be resolved. Just as is the case with other U-4 filing requirements, the disclosure difference should be resolved within 30 calendar days from the date the flag is set via the submission of either a U-4 Amendment or Concurrence Filing. The firm that submitted the U-4 Filing with the altered DRP details may decide to submit a U-4 Amendment to amend the DRP to match the details of the DRP that initially reported the disclosure event. Or, the "other" firm submits a Concurrence Filing to concur with and adopt the most recent DRP submission thus resolving the disclosure difference. Alternatively, all firms may agree on new language that's acceptable to all and that doesn't materially change the context of the disclosure. In that scenario, one firm would file a new DRP and the others would concur by filing Concurrence Filings.

Next Steps

Regardless of whether the disclosure difference is resolved via a Concurrence of an Amendment Filing, or even a combination of both filing types, the new filing(s) will be reviewed by Disclosure Review staff to determine if it does, in fact, resolve the disclosure difference. In the event the filing(s) resolves the disclosure difference, Disclosure Review staff will remove the Material Difference Flag and resolve the outstanding disclosure letters. If the filing(s) does not resolve the disclosure difference, Disclosure Review staff will resolve the existing disclosure letters and send new letters explaining why the disclosure difference is not deemed to be resolved and once again ask for resolution.

In the event firms are not able to reach an agreement and resolve the disclosure difference within 30 calendar days, Disclosure Review staff will refer the matter to a state regulator or NASD Regulation's Member Regulation or Enforcement staff, as appropriate for review and resolution, based on the facts and circumstances of the situation. The matter will be referred to the appropriate state regulator in cases where the individual is dually registered with investment adviser firms only (IA/IA). The matter will be referred to the appropriate NASD Regulation Department in all other dual registration scenarios (i.e., BD/BD and/or BD/IA).

Where can you view the Material Difference Flag

The fact that the Material Difference Flag has been set to "yes" will be viewable in:

The individual's Composite record in CRD
The specific disclosure occurrence in CRD which triggered the flag
The Individual Snapshot Report

In the event a public investor (or other person) requests a Public Disclosure Report on a registered representative before the disclosure difference is resolved, Disclosure Review and Public Disclosure staff will ensure that the requester is made aware of the conflicting or inconsistent information by providing the requester with a Public Disclosure Report that contains both versions of the information submitted whenever such a difference has been identified. Once the disclosure difference is resolved, the representative's Public Disclosure Report will appear similar to the way it did prior to the disclosure difference in that it will display the disclosure details from the most recent U-4 DRP submission (i.e., the Composite U-4 DRP).

What Is Disclosure Matching?

Disclosure Matching is a new review process for filings submitted on behalf of investment adviser-only representatives (RAs) that contain information submitted on Forms U-4 and U-5 Disclosure Reporting Pages (DRPs). Although, it will be the responsibility of each jurisdiction to perform the review of the disclosure information for investment adviser-only individuals, the Disclosure Review Analysts in the CRD/Public Disclosure Department will perform a limited review of the disclosure information submitted by the IA representative (RA) for two purposes only:

To create a new disclosure occurrence for the DRP or "match" it to an existing disclosure record (occurrence) if it has already been reported to CRD.
To identify the appropriate dates for disclosure information that is only required to be reported for a specified time (bankruptcies, certain customer complaints) in order to set the "reportable" and "disclosable" flags so that the event can be archived at the expiration of the reporting time period.

During the Disclosure Ma