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Financial Services Law Insights and Observations

FINRA updates guidance on verification of Form U4 for individual registration

Federal Issues Covid-19 FINRA

Federal Issues

On May 15, FINRA updated its response to a frequently asked questions regarding verification on Form U4 for individual registration. Under FINRA Rule 3110(e), members are required to have written procedures to verify the accuracy and completeness of an applicant’s initial or transfer Form U4 within 30 calendar days after the Form U4 is filed with FINRA. In light of challenges posed by Covid-19, if a firm is unable to verify the information within 30 days following submission, the firm must document which information could not be verified and the reasons and maintain an appropriate record, including steps taken to verify the information. For an initial or transfer Form U4, firms should make reasonable efforts to verify the information contained therein by June 30, 2020, and, if necessary, file an amended Form U4 to correct any discrepancies.

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