Transitioning Existing IA Representatives

IA firms should register IA representatives (RAs) electronically on Web CRD as directed/mandated by states. Firms may also do so voluntarily. IA firms that have IA representatives who are currently registered with state(s) must first “transition” the representatives’ registration statuses onto Web CRD prior to filing an electronic Form U4 Amendment. By first transitioning an existing IA representative (RA):

• The firm establishes a CRD record containing the IA representatives existing state registrations.
• The state(s) will be able to validate the registration and enter the date the individual first became registered with that state.
• The firm will avoid being charged duplicate state registration fees it has already paid for that IA representative.

Helpful links regarding the transitioning of an existing IA representative:

• NASAA's IARD: IA/BD Exemption Chart
• Investment Adviser Representative (RA) Form Filing Scenarios
• IA Representative (RA) Transition Navigation Guide
• IA Firm User’s Manual - Chapter 8: Transitioning Investment Adviser Representatives (RAs) and Individual NFI

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