Form Filing: IA Representative Registration
CRD allows IA firms to create and submit electronic filings of Forms U4 and U5 to fulfill the state regulatory registration requirements of investment adviser representatives (RAs). IA firms should register their IA representatives electronically in CRD as directed/mandated by states. Firms may also do so voluntarily. On this page are links to:
- The current version of the Uniform Forms U4 and U5 available from the FINRA website.
- Information regarding state participation in the electronic filing of IA representatives.
- Information regarding filing types for individual registration.
- User support tools available to help guide you through an Individual Form Filing.
Form Filing: New York IA Representative Registration
Updated July 23, 2021
Effective February 1, 2021, the State of New York (NY) began registering Investment Adviser Representatives (IARs) in CRD. On February 1, Forms U4 and U5 were updated to allow firms to select, under Section 5 of Form U4, RA registration in NY. While Web EFT is being updated, it is recommended that firms not use EFT to request NY IAR Registrations until the transition is completed. The system will go back to the default requirements on September 7.
From February 1 until July 30, 2021, NY will offer both noticed and registered NY investment adviser firms an offline “mass registration” process in an effort to help facilitate bulk RA registration. Firms with 20 or more IAR applicants, who are currently registered in CRD with your firm in another capacity (e.g., GS, AG, RA in another jurisdiction) and who satisfy NY’s RA exam or exam waiver requirements, may take advantage of this process.
Beginning February 27, 2021, FINRA Gateway will be temporarily updated so that windows for NASAA’s Series 65 examination will not systematically open when NY RA is the only registration requested on the filing (selection of other RA registrations will trigger any necessary exam requirements). If an individual requesting NY RA needs to take the Series 65, the firm will need to explicitly select the exam in Section 7 of Form U4 in order for the enrollment/window to be generated and the applicable fee to be charged. The automatic generation of Series 65 enrollments/windows when NY RA is requested will be re-enabled at a future time.
FINRA highly recommends firms utilize NY’s offline mass registration process to obtain RA registration in NY, in lieu of filing online through FINRA Gateway, or via Web EFT. By utilizing this off-system process, firms can ensure that NASAA’s Series 65 examination windows/enrollments will not systematically generate in CRD for those individuals who may otherwise be waived by NY from taking (or re-taking) the Series 65. If your firm files Forms U4 on FINRA Gateway, the system will enforce existing RA examination requirements and the applicable examination windows/enrollments may open and corresponding examination fees will be debited from your firm’s Flex-Funding account.
FINRA Gateway Reports now offers templates designed to support firms throughout the NY RA registration process. The four new report templates identify individuals who:
- may be subject to the registration requirement,
- have a NY RA registration requested,
- have an approved NY RA registration and have opened an exam enrollment.
For more information, see the FINRA Gateway Reports page.