Quick Answer
Registration is not a one-time event. An agent must promptly correct any filed document that becomes materially inaccurate, keep Form U4 current within specific deadlines, and renew registration every year by December 31. Both the agent and the employing broker-dealer share responsibility for these ongoing duties.
Once an agent is registered, the obligations do not stop. The USA imposes ongoing duties to keep filings current and accurate, and registrations must be renewed annually.
Correcting Amendments
- If information in any document filed with the Administrator becomes inaccurate or incomplete in any material respect, the registrant must file a correcting amendment promptly, unless notification of the correction has already been given as a change-of-connection notice
- This applies to all agents as registrants
- Material changes requiring amendment include:
- Change of address (residential or business)
- New disciplinary history
- Criminal charges or convictions
- Customer complaints
- Financial judgments or liens
Exam Tip: Gotchas
- A change of employment is the one thing this duty does NOT add. Beginning or terminating a connection with a firm is already covered by the separate change-of-connection notice, and the correcting-amendment duty carries an express carve-out for anything already notified that way. So an agent who moves firms and gives the required notice does not owe a second correcting amendment for the move itself.
Keeping Form U4 Current
- Both the agent and the employing broker-dealer (BD) must ensure the Form U4 stays current and accurate
- An agent who is charged with a felony must update promptly; you do not wait for a conviction
- Failure to update Form U4 is itself a violation that can lead to disciplinary action against both the agent and the BD
The USA's "promptly" standard does not itself set a day count. FINRA fills in the number of days for Form U4 amendments:
| Amendment Trigger | Filing Deadline |
|---|---|
| General reportable events (address change, customer complaint, financial judgment, regulatory action) | 30 days after learning of the event |
| Statutory disqualification events (certain felony and misdemeanor convictions, court injunctions, regulatory bars) | 10 days after the event |
Exam Tip: Gotchas
- Both the agent and the broker-dealer (BD) must ensure timely Form U4 updates. Failure by either party is a violation.
- A felony charge triggers the duty to update. You do not wait for conviction.
- The general rule is 30 days; the expedited rule for statutory disqualifications is 10 days. A felony charge is not yet a statutory disqualification (that is a narrower, conviction-based concept), so it runs on the ordinary 30-day clock.
Registration Expiration and Renewal
- Every agent registration expires December 31 unless renewed
- Renewal requires filing the appropriate renewal application and paying the renewal fee before the expiration date
- If an agent's registration lapses and the agent continues to transact business, the agent is acting as an unregistered agent in violation of the USA's registration requirement
Exam Tip: Gotchas
- All registrations expire December 31, no exceptions. An agent who continues transacting after a lapsed registration is acting unlawfully.
- Failure to update Form U4 is itself a separate violation. The exam may present this as a standalone infraction, apart from whatever triggered the need for the update.
What Should You Check on Exam Day?
- A correcting amendment is owed promptly for any material inaccuracy, except a change of connection already covered by the separate notification duty
- Form U4 amendments are due within 30 days for general reportable events, 10 days for statutory disqualification events
- A felony charge (not yet a conviction) still triggers the 30-day clock, not the 10-day one
- Registration expires every December 31 unless timely renewed
- Both the agent and the employing BD share responsibility for keeping filings current