FINRA CRD Registration Compliance Checklist

Submit complete Form U4 through WebCRD for all associated persons who will engage in securities business. Form must be filed and approved by appropriate SROs before individual begins soliciting orders, opening accounts, or conducting securities activities. Ensure all required sections are completed.

Submit fingerprints to approved vendor for FBI and state criminal history background check before filing Form U4. Fingerprints must be processed through FINRA-approved vendor using CRD number. Background check must be completed and clear before securities activities begin.

Review all 14 Disclosure Reporting Pages (DRPs) on Form U4 with associated person to ensure accurate and complete responses. Obtain documentation for any 'Yes' answers. Common disclosure events include criminal charges, regulatory actions, civil judicial actions, customer complaints, terminations for cause, and financial issues.

Ensure associated person has passed all required qualification examinations before beginning securities activities in specific capacities. Common exams: Series 7 (General Securities Representative), Series 24 (General Securities Principal), Series 63 (Uniform Securities Agent State Law), Series 65/66 (Investment Adviser).

Select correct registration categories based on functions to be performed: General Securities Representative (GS), Investment Banking Representative (IB), Research Analyst (AR), Operations Professional (OP), Limited Representative (LR), Principal (PR), or Investment Adviser Representative (IAR). Ensure qualifications match categories.

Identify states where associated person will conduct securities business based on client locations. Submit Form U4 state registration selections through CRD and pay state fees. Maintain current state registrations for all states where business is conducted or office is located.

Monitor for disclosure-triggering events including criminal charges, regulatory investigations, customer complaints over $5,000, civil litigation, bankruptcy, tax liens, and judgments. File amended Form U4 within 30 days of learning of reportable event, including complete DRP with detailed explanation.

File amended Form U4 within 30 days of changes to residential address, employment history, or other non-disclosure information. Maintain complete 10-year employment history. Document verification of residence through driver's license or utility bills.

Document procedures covering initial Form U4 review and approval, disclosure event monitoring, amendment timelines, supervisor review and sign-off requirements, escalation procedures, and recordkeeping. Assign specific individuals responsible for CRD administration and compliance.

Review all active Form U4 registrations quarterly to verify accuracy, completeness, and continued appropriateness of registration categories. Verify all required state registrations are current. Document review and remediate any identified deficiencies within 30 days.

When associated person's registration terminates for any reason, file complete Form U5 through WebCRD within 30 days. Include accurate termination reason code, full termination explanation, and complete any required DRPs for termination-related disclosure events (terminations for cause, customer complaints).

Within 30 days of filing Form U5, provide terminated associated person with copy of Form U5 filed on their behalf. Obtain written acknowledgment of receipt. Associated person has right to review and comment on Form U5 before filing.

Establish WebCRD access controls limiting Form U4/U5 filing, review, and approval to authorized compliance personnel. Document user roles, implement dual approval for filings, maintain audit logs of all CRD system access and changes. Review user access quarterly.

Establish process requiring associated person to review and sign attestation confirming accuracy and completeness of Form U4 before initial filing and annually thereafter. Designated principal must independently review and approve Form U4. Maintain attestations in compliance files.

Review FINRA BrokerCheck reports for all registered representatives monthly to identify any disclosure items appearing on BrokerCheck that were not reported on Form U4. Investigate discrepancies and file amended Form U4 if additional disclosure required.

File Form U4 amendment reporting written customer complaints alleging sales practice violations involving $5,000 or more in damages. Report all arbitrations and civil litigation regardless of amount. Include complete facts, allegations, current status, and firm's response on DRP.

Retain copies of all Form U4 filings and amendments, attestations, disclosure event documentation, background check results, qualification exam records, state registration confirmations, and supervisory review documentation for minimum six years after termination.

Identify and report statutorily disqualifying events requiring FINRA approval for continued association: felony convictions, securities-related misdemeanors, SEC/CFTC/state regulatory bars or suspensions, SRO expulsions or bars. File Form U4 amendment and MC-400 application if continued association sought.

Pay initial and renewal CRD processing fees ($85 initial, $100 annual), FINRA registration fees ($140), and applicable state registration fees. Monitor CRD billing system for payment due dates. Late payments result in registration lapses prohibiting securities activities.

Provide annual training to all registered representatives on Form U4 disclosure obligations, reportable events, amendment requirements, and consequences of false or misleading statements. Document training completion. Include case studies of common disclosure failures.