Frequently Asked Questions About Firm Form Filing in CRD
1. How do I submit form filings to CRD?
Upon completion of a filing, select the "Submit Filing" hyperlink on the left-hand margin. By selecting this hyperlink, a completeness check will automatically run. If the completeness check is successful, a "Submit Filing" button will display. It is very important to select this button to completely submit the filing to CRD. Once this button has been selected, a message will display that the filing has been Successfully Queued for Submission. At this time an "OK" button will be displayed. You may select this "OK" button to submit another form filing or perform other actions in CRD.
2. How long does a filing remain "pending" in CRD?
"Pending" U4, U5, BDW and U6 filings will remain "pending" in CRD for a period of two months, and "pending" BD filings will remain for six months. If they are not submitted during that timeframe, the system will automatically delete them after they reach their expiration date. It is important to review your Pending Filing Queue on a regular basis to ensure that pending filings are completed and submitted prior to CRD deleting the pending filing. You can retrieve your pending filings by selecting the Forms Menu Item, selecting a filing type sub menu item (U4, U5, BD, BDW or U6), and then selecting the Pending tab. Using the "Pending Filings Search Criteria" Screen, you can sort by Filing Creation Date in either Ascending or Descending order. You should review the filings with older Creation Dates in order to identify those that you wish to submit.
3. Where can I find the CRD "picklists" for the Uniform Registration Forms?
The picklists can be found on the Registration Forms page in the appropriate Instructions document.
4. Should titles (i.e., Mr., Ms., etc.) be captured in any of the name fields on the Uniform Forms?
When creating an individual and inputting the individual's name, DO NOT use titles such as Mr., Mrs., Ms., etc., in any of the name fields. As CRD cannot perform a completeness check on these fields since they are free text fields, the titles are stored as part of the name itself, which can prevent or delay a match when a name search is performed.
5. How do I go about changing my firm's name?
Section 1D of Form BD, Application Information, is for firms that are changing names, and it says check the box for Applicant Name (1A) or Business Name (1C). In most cases, firms are changing both, in which case they should select both boxes. See the CRD quick reference guide Organization Form Filing: Form BD page for more information.
FINRA-registered firms should contact Disclosure Review prior to changing their names as they must receive approval before submitting a Form BD. See the Reserving a Firm Name page for additional navigational instructions.
In addition, the name change will not take effect in CRD immediately; there is a 10-day "grace period" during which FINRA notifies the jurisdiction of the impending change.
6. Is it possible to post-date the opening of new branch offices?
No, new branch offices that are opening cannot be post-dated. Firms must wait until the day the branch opens to submit the Form BR. See the Branch Office Registration FAQ and the quick reference guide Registration Filing in FINRA Gateway - Enhanced Form BR Filing Experience Summary of Changes for more information.
7. How do I remove a person from Schedule A or B?
The first sentence that will appear on an existing control person's record is: "Check here to terminate this Owner." To remove a person from Schedule A or B, check the Check Box next to this sentence and select Save. Keep in mind that there must be at least one direct owner on Schedule A at all times. See the quick reference guide Organization Form Filing: Form BD for additional navigational information.
8. Does a trustee need to be listed on Schedule A and/or B?
If a trust is listed as a Direct Owner/Executive Officer on Schedule A, each trustee must also be listed on Schedule A.
If a trust is listed as an Indirect Owner on Schedule B, each trustee must also be listed on Schedule B.
9. When filing a Full BDW, can the "Custodian of Books and Records" be a firm?
For FINRA-registered firms, the Custodian of Books and Records must be an individual, not a firm. If you place a firm in that field, it will trigger a filing deficiency.
10. When responding to question 5 on Form BDW should I complete items A through D?
If question 5 is answered “Yes,” items A through D should be completed.
If question 5 is answered “No,” no data is required in items A through D.