IARD System Frequently Asked Questions - Form Filing for IA Representatives
Qualifications (including Exams & Professional Designations)

1. What are the qualifications for an IA representative (RA) registration?

To be deemed qualified for the RA registration category, the system requires that an individual meet one of the following criteria:

1. Have a passing grade for the S65 within the past two years; or
2. Have a passing grade for the S66 within the past two years and a passing grade for the S7 within the CRD continuous registration period or two years prior to the beginning of the continuous registration period; or
3. Have a passing grade for the S66 within the past two years and a GS/TR/TS within the CRD continuous registration period; or
4. Currently hold one of the system-recognized professional designations; or
5. Have held an approved RA registration with any jurisdiction within the past two years.

With regard to the five professional designations (CFP, CFA, CIC, ChFC and PFS), three of the Designating Authorities will send, on a regular basis, a file of all the current holders of that designation. Two of the Designating Authorities (AICPA and AIMR) have sent partial lists. If a Form U-4 is submitted with any of those designations indicated, the system will check against the most recent information received from the Designating Authority to confirm that the applicant is "on the list." If the applicant is not on the list, the filing will fail the Completeness Check and the system will prevent the Form U-4 from being submitted. At that point, a submitter has two choices. If the applicant holds the designation, he or she should call the Designating Authority and request that the Authority send an updated electronic file to FINRA (which includes that individual). These files can be submitted as frequently as once a day and will be processed by FINRA overnight. The submitter can send the Form U-4 again, at which point it should not fail the designation Completeness Check. If the applicant does not hold the designation, the submitter should uncheck that professional designation box and resubmit the Form U-4.

With regard to qualifying via registration in another jurisdiction, that registration would have to be posted on the CRD system. If the applicant qualifies because he or she held an approved RA registration with any jurisdiction within the past two years, a notice of the application will appear in the state’s Manual Approval Queue. The state can then determine whether the qualification meets the state reciprocation requirements. If not, the state will notify the applicant that the individual will have to pass the qualifying exam for that state.

For more information, see the IA Firm User's Manual posted on this Web Site.

2. Is a firm eligible to receive a refund for the Series 65 Exam if it selected RA positions PRIOR to transitioning the individual onto the system?

Yes. A firm may receive a refund if it filed a Form U-4 Amendment before it had transitioned the individual’s current registration information onto CRD. The firm must contact the state directly and ask the state to contact FINRA to authorize the refund of the exam fee. FINRA cannot refund the exam fee without the state’s authorization.

3. How far back does the exam history information go when a Form U-10 is linked in CRD?

The exam history reflects all exam data on the Proctor System. For any Form U-4 Filing request, the system will check to see if the Series 63, 65, and 66 exams were taken via a Form U-10 and bring the information into CRD.

4. Does a Professional Designation waive the Series 7 for an individual seeking to be GS registered?

No. A Professional Designation does not exempt an individual from the Series 7.

5. What Professional Designating Authorities participate in the system for the registration purposes of IA representatives?

• 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, PA
• 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 Adviser Association

6. Are Professional Designations accepted in every state as an alternate qualification requirement?

Although the system currently accepts Professional Designations for every state that registers investment adviser representatives, firms should contact each state to confirm whether it accepts a given designation in lieu of the qualifying examination.

7. I attempted to submit a Form U-4 filing with a Professional Designation(s) and the filing is not going through. I am receiving a Completeness Check error message. What should I do?

Contact the Professional Designating Authority directly to verify the Designation(s) and have the Professional Designating Authority send the updated information to FINRA via an electronic file. Once CRD processes the information, the firm may re-submit the pending Form U-4 filing with the Designation and will no longer receive the error message.

8. Release 4.0, which was implemented March 18, 2002, added "Current Professional Designations" to View Individual. What information appears there?

"Current Professional Designations" lists the Professional Designations indicated on the most recent Form U-4 filed on behalf of an individual. Upon submission of a Form U-4, the system confirms that the individual is included on the most recent listing of designees from the relevant Designating Authority. The designation will continue to appear even if it is no longer valid, until a Form U-4 Amendment is filed without that designation indicated. Conversely, if a subsequent Form U-4 Filing omits that designation even though the individual holds it, the designation will no longer appear.

Please note: Firms and investment adviser representatives are under a continuing obligation to update their Form U-4; accordingly an investment adviser representative should amend Form U-4 if he/she reported holding a Professional Designation and that designation has been revoked, suspended or has lapsed.

9. An individual is registered as an AG with a BD firm and as an RA with an IA firm. He holds a Professional Designation that the IA firm indicated when filing the Form U-4 for the individual. When the BD firm attempts to file a Form U-4 Amendment to update his record, he receives a completeness check indicating that the firm cannot select a professional designation without also selecting an RA position. What can the BD firm do to avoid this completeness check message and submit a Form U-4 Amendment?

The BD firm needs to uncheck the Professional Designation when submitting the Form U-4 Amendment. When the IA firm needs to update the individual's registration for any reason, it can re-check the appropriate Professional Designation at that time. The firms will have to continue to check and un-check the Professional Designation box as necessary to pass the Completeness Check.

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