State Participation in CRD Form BD and BDW Processing

*These are suggested departments only. Others may be appropriate for your firm.

EXECUTIVE SUMMARY

State participation in CRD Phase II, the Form BD (Uniform Application for Broker-Dealer Registration) and Form BDW (Uniform Request for Broker-Dealer Withdrawal) processing phase of the CRD system will begin February 1, 1989. Effective that date, members will be able to report Form BD changes to the NASD and participating states by submitting only one Form BD amendment to the CRD, instead of submitting a Form BD amendment to each state jurisdiction. A single Form BDW also may be filed with the CRD to initiate a request for full broker-dealer termination with all participating states or partial termination in only selected participating state(s). Certain states also will permit application for initial broker-dealer registration to be started via CRD.

BACKGROUND

Form BD is the primary broker-dealer application used by the NASD and the states. Once registered, firms are under a continuing obligation to keep current the information reported on Form BD. Traditionally, this has required that firms file

Form BD amendments directly with each state. The February 1 expansion of CRD Phase II marks the beginning of the centralized processing of Forms BD and BDW. In a manner similar to the processing of Forms U-4 and U-5, the CRD will process Form BD amendments and Forms BDW and disseminate the information disclosed on the filing to participating state jurisdictions.

FILING REQUIREMENTS

This notice includes a chart indicating the states that will begin participation in Phase II on February 1, 1989. All states listed as participants will accept the Form BD amendments and Forms BDW filed with CRD in place of an original filing made directly with their offices. The chart also reflects current state broker-dealer initial registration filing fees and indicates whether the state will collect these fees through CRD.

• Form BD Amendments — Members may submit a single Form BD amendment to the CRD to report all Form BD updates to the NASD and the participating states in which they are registered.
• Form BDW — A single Form BDW may be submitted to the CRD to request full termination of registration with the NASD and all participating states. Members seeking to effect only a partial termination of registration in one or more participating states also may file an appropriately completed Form BDW with the CRD to initiate a request for state-only termination.
• Initial State Broker-Dealer Registration —States generally will require that information be filed directly with them to effect initial registration. However, many states have designated the CRD for the collection of initial broker-dealer registration fees. Each participating state will be distributing a notice detailing the nature of its participation in Phase II of the CRD system. Since these notices will be directed only to current registrants, members interested in expanding registration into additional jurisdictions should contact the appropriate states to ascertain their requirements and their use of CRD as part of the application process.

Questions regarding this notice should be directed to NASD Information Services at (301) 590-6500.

CRD PHASE II PARTICIPANTS AS OF DECEMBER 15, 1988

Note: CRD collection of state initial registration fees will be accomplished by submission of Pages 1 and 2 of Form BD along with the designated fees. Please contact the appropriate state(s) to determine any additional filing requirements. (Y= yes; N= no).