CRD FAQ - Disclosure

1. I am doing a Pre-Registration Search for an individual who was once registered but who has not been in the business since 11/96. What must I check to see if the individual has any disclosure?

When doing a Pre-Registration Search on an individual who has not been registered since 11/96, always check the Legacy Disclosure page of the individual’s CRD record. Disclosure information for individuals who were terminated as of 11/96 was not converted in the standard CRD format and will only appear in Legacy disclosure. See the View Individual Quick Reference Guide for more information.

2. How do I review a Disclosure that has not yet been reviewed by the FINRA Disclosure Review staff?

Disclosures will not be available to view in Individual Query until they have been matched to an occurrence. Users can view the disclosure prior to this in two places:

1) the user can access Filing History and view the disclosure on the Form Filing, or

2) the user can look at the disclosure in their Disclosure Notice Queue. From this queue the user can link to the disclosure. See the View Individual Quick Reference Guide and the Firm Queues for Individuals Quick Reference Guide for more information.

3. What do the Exact or Explanation Date radio buttons mean on the Disclosure Reporting Pages (DRPs)?

Where indicated on the DRPs, the date fields require the user to enter a date and indicate if the date is an exact date or an approximation of the date on which the event occurred. If the date is an approximation of the date, enter the approximate date in the format MM/DD/YYYY in the date field, mark the radio button titled 'Explanation' and provide an explanation in the text block. If the exact date is known, enter the date and mark the "Exact" radio button.

4. Should the disclosure questions be answered when submitting a Partial Form U5?

When filing a Partial Form U5, you will not have access to the disclosure questions. They are not required to be answered when submitting a Partial Form U5 because all updates to an individual's disclosure information are reported through a Form U4 when an individual has any active registration with the firm.

5. What is the Material Difference Flag and whom does it affect?

The Material Difference Flag applies to dually registered individuals (RR/RR, RR/RA or RA/RA). This flag is set whenever an unresolved difference exists in any of the factual fields of the DRPs for the same disclosure event. The flag acts as a notification to regulators that a difference exists.

Pending registration requests will not be approved until the difference is resolved. If the Material Difference Flag is not resolved by the respective filing firms within 30 days, the appropriate regulator(s) will be notified.

If you have questions regarding an occurrence that has a Material Difference, contact the Gateway Call Center at (301) 869-6699 and ask to speak to a Disclosure Review Analyst.

6. What do the Statutory Disqualification (SD) codes used in the CRD program mean?

Please see the Statutory Disqualification Codes page for complete definitions.

7. How do I map the U4 Disclosure Questions to the corresponding DRPs?