How to Complete FINRA Registration Forms: U4, U5, BD, and BR

Completing FINRA registration forms means working through the CRD system: a FINRA-member broker-dealer files each form electronically on behalf of the individual or entity being registered, using FINRA Gateway at gateway.finra.org.¹ Form U4 registers an associated person, Form U5 terminates that registration, Form BD registers the broker-dealer itself, Form BR adds a branch, and Form BDW withdraws the firm. Form U6 sits apart because regulators, not firms, file it. Each form has its own records to assemble, its own disclosure questions, and its own deadline, and the filing will not process until the firm’s Flex Funding Account holds enough to cover the fee.

Form U4: Registering an Individual

Form U4, the Uniform Application for Securities Industry Registration or Transfer, is filed by a FINRA-member broker-dealer for anyone entering the industry as a registered representative or principal. The applicant does not file it themselves.²

Records to Gather Before You Start

Before the firm inputs the filing, the applicant needs a continuous employment history for the past ten years with no gap longer than three months. That history must account for full-time and part-time work, self-employment, military service, homemaking, unemployment, full-time education, and extended travel. Residential addresses for the past five years are also required, again with no gaps exceeding three months, and post office boxes are not acceptable.³

To sit for a qualification exam like the Series 7, the applicant must first be sponsored by a broker-dealer. The SIE can be taken without sponsorship, and a passing SIE score stays valid for four years.⁴

Fingerprints

Under Section 17(f)(2) of the Securities Exchange Act of 1934 and SEC Rule 17f-2, firms must submit fingerprints for all partners, directors, officers, and employees unless the person falls into a narrow exemption. Prints can be collected on FINRA-specific hardcopy cards or electronically through a FINRA-approved vendor, and they are processed through the FBI.⁵

The exemption applies only to employees who do not sell securities, do not regularly access securities, money, or the firm’s original books and records, and do not directly supervise anyone who does. All three conditions must be met. Being a foreign national or residing outside the United States does not create an exemption. If someone cannot be fingerprinted because of a physical disability, the firm can submit a written request to the SEC’s Division of Trading and Markets.⁵

Section 14 Disclosures and DRPs

Section 14 is where filings usually stall. It asks yes-or-no questions about criminal history, regulatory actions, civil litigation, customer complaints, financial events like bankruptcies and unsatisfied judgments, and terminations from prior firms. Any yes answer triggers a Disclosure Reporting Page.² Each DRP must include specific dates, the names of courts or regulatory bodies involved, and the final outcome. Have original court documents and regulatory orders on hand before starting the filing; vague or incomplete DRPs are a common reason filings hold up.

The disclosure obligation extends to federal tax liens and unsatisfied civil judgments. An associated person who receives an IRS tax lien or is subject to an outstanding judgment must amend their Form U4 to report it, and failing to do so is a violation of FINRA rules regardless of intent.⁶

Keeping the U4 Current

Form U4 is not a one-time filing. Under FINRA’s bylaws, every registration must be kept current through supplementary amendments filed no later than 30 days after learning of the facts that trigger the change.⁷ That clock applies to new criminal charges, customer complaints, changes of address, outside business activities, and any other material development. The firm is responsible for verifying accuracy before submitting. Discrepancies in employment dates or missing address information can prompt formal inquiries from FINRA staff.

Form U5: Terminating a Registration

When a registered person leaves a broker-dealer for any reason, the firm files Form U5, the Uniform Termination Notice for Securities Industry Registration, within 30 days of the individual’s last day. The firm must also give the departing person a copy of the filed Form U5 within that same 30-day window.⁸

The form requires the firm to pick a reason for the separation from a fixed set of categories: Voluntary, Discharged, Permitted to Resign, Deceased, or Other.⁹ The choice matters. A termination coded as “Discharged” or “Permitted to Resign” may trigger additional disclosure obligations and will appear on the individual’s BrokerCheck record. If the separation involved allegations of misconduct, sales practice violations, or regulatory issues, the firm must complete Disclosure Reporting Pages explaining the circumstances.

Once a Form U5 is filed, the individual’s registrations end. To re-enter the industry, a new firm must file a fresh Form U4 on their behalf.¹⁰

Form BD: Registering a Broker-Dealer

Any person or firm acting as a broker or dealer must register with the SEC using Form BD, the Uniform Application for Broker-Dealer Registration, as required by 17 CFR 240.15b1-1.¹¹ The form collects information about ownership structure, control persons, types of business to be conducted, and legal history. Filing Form BD is the gateway to SEC registration, FINRA membership, and state registration.

For a new firm seeking FINRA membership, Form BD is one piece of a larger package. The firm must also submit Form U4 filings for each person who will be registered, fingerprint cards for associated persons subject to SEC Rule 17f-2, a new member assessment report, a contact questionnaire, and the appropriate fee. A second part of the application goes to FINRA’s district office and includes a detailed business plan with twelve-month financial projections, an organizational chart, a description of intended office locations, the types of securities to be offered, and the methods the firm will use to develop customers.

Form BR: Registering a Branch Office

Firms must register each branch office with FINRA, the NYSE, and any state that requires branch registration by filing Form BR, the Uniform Branch Office Registration Form.¹² The form identifies the physical address where securities business is conducted and the supervisor responsible for the location. It is filed through FINRA Gateway, which also handles notice filings with participating jurisdictions.¹³

The initial registration fee is $105 per branch plus a $75 system processing fee. FINRA waives both for a firm’s first branch office.¹⁴ Branch registrations must be kept current to reflect closures, relocations, and changes in supervisory personnel. Letting a registration go stale while continuing to conduct business from that location creates a compliance problem examiners will flag.

Form BDW: Withdrawing a Broker-Dealer Registration

When a broker-dealer wants to stop doing business, it files Form BDW, the Uniform Request for Broker-Dealer Withdrawal, through the CRD. Before filing, the firm must first amend its Form BD to correct any incomplete or inaccurate information.¹⁵

A firm seeking full withdrawal must also file a copy of its FOCUS Report, or FOCUS Report Part IIA for non-carrying firms, showing its statement of financial condition and net capital computation. The financial data must reflect the firm’s position no earlier than ten days before the Form BDW is filed. Firms that do not file FOCUS Reports submit a general financial statement listing type and amount of assets, liabilities, and net worth. The firm must retain a paper copy of the Form BDW with original signatures, along with the initial Form BD and any Disclosure Reporting Page amendments, and make them available on regulatory request.

Form U6 Is Not a Firm Filing

Form U6, the Uniform Disciplinary Action Disclosure Form, is filed by regulators rather than by broker-dealer firms. FINRA, other self-regulatory organizations, and state jurisdictions use it to report disclosure events and disciplinary actions against individuals and firms, and FINRA also uses it to report final arbitration awards against broker-dealers and their associated persons.¹⁶ Actions reported this way, such as fines, suspensions, bars, cease-and-desist orders, and revocations, flow directly into the CRD and appear on BrokerCheck. Firms and individuals cannot alter that data, but they can submit a comment for the record through BrokerCheck.

Filing Mechanics: Gateway, Fees, and Timing

Every CRD registration form is submitted through FINRA Gateway. An authorized signer at the firm provides an electronic signature verifying the accuracy of the filing, and the system’s dashboard tracks status and confirmations.¹

Fees

The initial Form U4 registration fee is $125 per individual. Branch office registration carries the $105 initial fee plus a $75 system processing fee, with both waived for the first branch.¹⁴ Qualification exam fees are assessed on top of the registration fee: the Series 7 exam costs $395 and the Series 14 (Compliance Official) exam runs $450.¹⁷

All fees come out of the firm’s Flex Funding Account. Firms can add money through E-Bill, ACH or wire transfer, funds transfer, or check. Check deposits received before 2 p.m. ET post the next business day; deposits after that cutoff take two business days.¹⁸ The account must have sufficient funds before a filing can process, so fund it well ahead of a batch of registrations.

How Long Filings Take

For new firm membership applications, FINRA has up to 180 calendar days from receipt of a substantially complete application to issue a decision.¹⁹ During the first 30 days, FINRA’s Membership Application Program conducts an initial review to determine whether the application contains enough information to begin a meaningful evaluation.²⁰ Individual Form U4 registrations at an existing member firm process faster, though incomplete disclosures or fingerprint issues can stretch the timeline.

When a U4 Disclosure Triggers Statutory Disqualification

Certain events on a person’s record trigger statutory disqualification, which bars that person from associating with a FINRA member firm. Under Section 3(a)(39) of the Securities Exchange Act, the disqualifying events include all felony convictions and certain misdemeanor convictions for a ten-year period from the conviction date, court injunctions related to securities activities regardless of age, bars or expulsions from any self-regulatory organization, and findings of willful violations of federal securities or commodities laws.²¹ State-level actions can also disqualify: a final order from a state securities commission, banking authority, or insurance commission that bars someone from association with a regulated entity, or that was based on fraudulent or deceptive conduct, counts as a disqualifying event. Associating with another disqualified person does as well.

Disqualification is not necessarily permanent. A firm that wants to hire or retain someone who is disqualified files Form MC-400, the Membership Continuance Application, under the FINRA Rule 9520 Series. The firm files it, not the individual, by emailing a completed PDF to SDGroup@finra.org. Before submitting, the individual must already have a Form U4 filed electronically with FINRA.²²

The MC-400 package is substantial. It must include copies of all documents related to the disqualifying event, a signed personal statement from the disqualified individual explaining both the circumstances and why they should be approved, a detailed outline of their industry experience, a written supervision plan, and an interim plan of heightened supervision. The firm must also identify the specific individuals who will serve as direct and alternate supervisors, including their CRD numbers, registrations, and any personal or financial relationships with the disqualified person.²²

1
FINRA. FINRA Gateway
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FINRA. Form U4
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FINRA. Form U4 Uniform Application for Securities Industry Registration or Transfer
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FINRA. SIE Exam and Exam Restructuring Frequently Asked Questions (FAQ)
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FINRA. Frequently Asked Questions (FAQ) About Fingerprint Processing
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FINRA. Decision in the Matter of Scott Mathis
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FINRA. Application for Registration
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FINRA. Form U5
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FINRA. Form U5 Uniform Termination Notice for Securities Industry Registration
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FINRA. How to Terminate Your Registration With FINRA
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eCFR. 17 CFR 240.15b1-1 – Application for Registration of Brokers or Dealers
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FINRA. Form BR
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FINRA. Frequently Asked Questions about Branch Office Registration
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FINRA. Schedule of Registration and Exam Fees
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SEC. Form BDW Uniform Request for Broker-Dealer Withdrawal
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FINRA. Form U6
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FINRA. Section 4 – Fees
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FINRA. CRD Payment Methods and Addresses
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FINRA. How to Become a Member – Membership Application Time Frames
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FINRA. Membership Application Program Group (MAP) Frequently Asked Questions
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FINRA. General Information on Statutory Disqualification and FINRA’s Eligibility Proceedings
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FINRA. Form MC-400 Membership Continuance Application