Updating information on my u4
FINRA has identified Form U4 and U5 reporting as an essential part of investor protection.(Would you take investment advice from a broker who has had questionable practices with respect to managing his/her own finances?
Each of these situations may be presented in FINRA review, but upon deeper investigatory efforts would truly be nonreportable events.
30, 2004); NASD Fines Morgan Stanley .2 Million for Late Reporting, Firm Temporarily Suspended from Registering New Brokers (July 29, 2004)
Key Recommendations: - Conduct a public records search Review public records for any judgments or liens against registered representatives.
If that causes you to stop and think twice, then you can understand why FINRA expects that investors need information relevant to their decision to work with a broker and why FINRA considers important information shedding light on a broker’s management (or lack of management) of his/her own financial situation, including paying outstanding debts.) In its Regulatory Notice 15-05, covering Rule 3110(e), FINRA states that firms should consider “all available information” in the pre-registration process.
FINRA also suggests member firms should consider using private background checks, credit reports and reference letters for this purpose.- It is expected that a variety of factors will be considered in assessing whether enforcement actions will be taken against firms based on unreported or late reported events.Factors include: number of registered representatives, the number of undisclosed events, and whether there are other aggravating factors, e.g., a prior disciplinary history or red flags.In addition, at a minimum, firms must conduct public record searches—a new, mandatory requirement—which includes reviews of an applicant’s criminal records, bankruptcy records, civil litigations and judgments, liens, and business records.