When is a firm expected to provide the required disclosure or disclosure documentation requested in the Inquiry Letter?
Under Article V, Section 2(c) of FINRA’s By-Laws, a member is required to keep Form U4 current by submitting supplementary amendments within 30 days of learning of the facts or circumstances giving rise to the amendment, or within 10 days if the amendment involves a statutory disqualification. The reporting requirement is triggered when a firm learns of facts or circumstances giving rise to an amendment; implementation of the 30-day Disclosure Inquiry Letter Tracking period in Release 7.0 does not change the timing of a firm’s reporting obligation. In most cases, a Disclosure Inquiry Letter does not trigger a firm’s reporting obligation, but instead serves as a reminder that a required Form U4 Amendment (or supplemental information) must be filed via Web CRD or provided to the staff. A firm should have appropriate compliance controls in place to ensure that it receives timely notice of information that triggers a reporting requirement. As a reminder, Web CRD’s Disclosure Review Queue p
Related Questions
- How is a contribution received by a political committee using a commercial fundraising firm to be reported on the committee’s campaign disclosure report?
- When is a firm expected to provide the required disclosure or disclosure documentation requested in the Inquiry Letter?
- How to Write a Letter of Inquiry
