IARD System Frequently Asked Questions - Form Filing for IA Representatives
General

1. What is the purpose of the Private Residence check box?

The private residence check box enables an individual to indicate to regulators on the Form U4 that his or her Office of Employment address is also a private residence. Regulators may then determine whether to disclose the address to the public, given privacy concerns.

2. Do IA representatives have access to the remote site (with passwords) to complete the Forms U4?

Yes.

3. Does a firm have to wait for a state to approve an individual who has transitioned before submitting the Form U4 Amendment filing for the individual?

No. The firm may submit the Form U4 Amendment filing before a state approves the Transition Filing.

4. An individual is leaving Firm A to work for Firm B. Firm B relicenses that individual and, in doing so, updates the DRP. Firm A has not yet submitted a Form U5 for that individual. What is Firm A's responsibility? Does Firm A need to concur or amend the information prior to submitting a Form U5?

Firm A must submit either a Concurrence Filing or an Amendment Filing before it terminates the individual while the firm association remains open. If Firm A does not concur or amend before it terminates the individual, the termination does not resolve the discrepancy. If Firm A does not concur or amend within 30 days, regulators will be consulted to resolve the discrepancy.

5. What filing type should I choose if my firm is hiring an individual as an RR, and the individual is only registered as an RA with another firm and plans to maintain the RA registration with that firm?

Your firm should submit a Dual Registration U4 Filing. If the firm is jointly registered, the firm should choose Amendment to add an AG registration.

6. Do the Form U5 rules apply to IA representatives (RAs)?

Yes. All Form U5 rules apply, EXCEPT the Form U5 late fee does NOT apply to IA representatives (RAs).

7. Are AGs exempted from filing RA registrations?

Firms should contact the states directly for information on state exemptions for RA registrations. Visit the NASAA website for more information.

8. Are User Manuals available for the IARD and Web CRD portions of the system?

Yes. The IARD Firm User’s Manual is posted on the IARD website. The Broker/Dealer Firm User’s Manual is posted on the FINRA website. PDF versions of each manual may be downloaded free of charge. In addition, a bound copy of the Broker/Dealer Firm User’s Manual may be purchased through FINRA Media Source at (240) 386-4200 (call for current price).

9. What is a Concurrence Filing?

A Concurrence Filing is a type of filing that allows a firm to submit a Form U4 Amendment concurring with, and thereby adopting, Form U4 changes submitted by another firm that employs the same individual. A Concurrence Filing may be filed when the following information is submitted by a firm employing a dually-registered individual:

  • Identifying information/Name Change
  • Other Names, Residential History
  • Employment History
  • Other Business
  • Disclosure Questions or DRPs.
The filing is a read-only filing; however, the Signature Section of the Concurrence Filing must be completed by the adopting firm in order for the concurrence to be effective.

10. Does the Investment Adviser Public Disclosure (IAPD) program include information about individual investment adviser representatives?

Yes. Among other changes ushered in with software release 2010.2 on June 28, 2010, was the expansion of the IAPD system to include information about individual investment adviser representatives. IAPD provides information regarding an individual’s professional background and conduct including current registrations, employment history, and disclosures about certain disciplinary events involving the individual. View the IAPD website for additional information.

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