Why was the Late Disclosure Fee established?
As outlined in Notice to Members 04-09 , the late fee is an additional mechanism to help ensure that members make required disclosures on Forms U4 and U5 in a timely manner. In this context, disclosure events generally refer to events that require affirmative answers to the questions on Forms U4 and U5 that elicit information about criminal actions, regulatory disciplinary actions, civil judicial actions, customer complaints, terminations, and financial matters (currently, Questions 14A-M on the Form U4 and Questions 7A-F on the Form U5). Disclosure events must be reported either 1) on an Initial (i.e., Initial, Dual or Relicense) Form U4 or Initial Form U5 filing, if the triggering event occurred prior to the date of such filing; or 2) on an Amendment filing within 30 days of a triggering event (10 days for events that subject an individual to statutory disqualification). The receipt of timely and complete information about members and their registered persons is essential to FINRA’s
