Guidelines for IA Comments on IAPD
Individuals who are not currently registered as an Investment Adviser Representative (IAR), but who (1) have been IAR-registered within the last two years or (2) have been the subject of one or more final regulatory actions (as defined on Form U4) may submit an Investment Adviser (IA) Comment Request Form to provide an update or add context to information disclosed through Investment Adviser Public Disclosure (IAPD). Individuals who are currently IAR-registered and wish to provide an update or add context to information disclosed through IAPD are required to file an amended Form U4 via Web CRD.
Individuals may submit an IA Comment to FINRA by submitting a completed, signed and notarized IA Comment Request Form, along with the section(s) of the IAPD report for which a comment is requested (highlighting or circling the specific section is sufficient). FINRA will review the request and add the comment to the individual's IA report if FINRA, in consultation with state regulators, determines the request meets the following criteria:
- The request is appropriate. At a minimum, the comment must not contain confidential customer information; offensive or potentially defamatory language; or information that raises significant identity theft, personal safety or privacy concerns.
- The request and comment relate to the information disclosed through IAPD.
- The request pertains only to the IAPD report of the individual submitting the request.
- The individual submitting the request is not currently IAR-registered.
FINRA, in consultation with state regulators, reserves the right to reject comments or redact certain information, on a case-by-case basis, that it deems to be inappropriate.
IA Comments that meet criteria discussed herein generally will be posted to IAPD within thirty business days of receipt. The IA Comment will be displayed in IAPD as long as the report is available to the public. An individual may replace or delete a previously submitted comment by submitting another IA Comment Request Form. If an individual becomes IAR-registered, a previously posted IA Comment will no longer display through IAPD and the individual must provide any updated information that was the subject of the IA Comment via a Form U4.
To submit the request, mail the completed, signed and notarized IA Comment Request Form and the circled/highlighted pages of your IAPD report to:
Registration and Disclosure—Registration Management
9509 Key West Avenue
Rockville, MD 20850-3329
Note: FINRA will not accept requests sent via facsimile.
Questions may be directed to the IARD Call Center at (240) 386-4848.