These are the instructions that were sent to investment advisers in April 2002.  If you know the number of representatives you have registered, you will not need a roster from the Division—just send the required fees to FINRA.

 INVESTMENT ADVISER REPRESENTATIVE IARD TRANSITION

 TRANSITION CHECKLIST

1. Review the enclosed Roster and make necessary corrections.

2. Send a check to FINRA for the correct amount.

3. Submit new Account Administrator Entitlement Forms to FINRA.

4. File Transition Registration for each RA on the Roster.

    DEADLINE: June 30, 2002

5. File electronic U-4’s for each RA on the Roster.

                        DEADLINE: July 31, 2002

TRANSITION PROCEDURE

A copy of a two-page Navigation Guide outlining the procedure is included with this mailing.  It is also found  online at http://www.iard.com/pdf/nav_ia_transition.pdf.  The IA Firm User’s Manual has detailed instructions, including screen shots.  A link to the manual can be found at http://www.iard.com/UserSupport.asp.  You will want to look at Chapter Eight, pages 115-119.  More detail on the Accounting Functions can be found in Chapter 13, pages 235-248.

 

1. Review the enclosed Roster and make necessary corrections.
   These are the RA’s we show as currently licensed or pending with your firm.  If this information is not correct, please contact Bruce Johnson at 360-902-8781 or via e-mail at bjohnson@dfi.wa.gov.  Please submit a U-5 for any persons who are on the roster but have terminated.
   
2. Send a check to FINRA for the correct amount.
   At the end of the list you will see a count of the RA’s and then a total that you will owe to FINRA (# of RA’s x $45).  After making corrections, write a check payable to “FINRA” for the correct total due.  Write the firm’s IARD/CRD Number in the memo line of the check.
   
   Mail the check to:
   FINRA Regulation, Inc. CRD-IARD
   PO Box 7777-W9995
   Philadelphia PA  19175-9995
   
   Express delivery should be sent to:
   FINRA Regulation, Inc. CRD-IARD
   W9995
   c/o Mellon Bank, RM 3490
   701 Market St.
   Philadelphia, PA  19106 (if a phone number is required, use 240-386-4848)
   
   Note:  The $45 fee applies to each affiliation an individual has with a firm.  So, for example, if an individual is an RA with a broker-dealer, and also has a separate registered investment adviser where the person is an RA, two $45 fees will be owed.  For future reference, the $45 fee will be owed on an annual basis, along with the State of Washington’s $20 renewal fee.
   
3. Submit new Account Administrator Entitlement Forms to FINRA.
   If you are the IARD Account Administrator and will also be doing the transition and U-4 filings, you may need to file a new Account Administrator Entitlement Form.  We have enclosed the form to be used by IA Only Firms.  (If your firm is also a Broker-Dealer, you probably have all the rights you need.)  If you wish to have entitlements to all the IARD functions (which you need if you are the only account administrator), you need to check all the boxes on the left side of the form.  Mail or fax the form to FINRA at the address/fax number listed at the bottom of the form.
   
4. File a Transition Registration for each RA on the Roster.
   A.  Check to see if your funds have been deposited.  After about ten days, check your Daily Account in IARD to see if the money has been credited.  Under the Accounting tab click on Deposit Detail under the Daily Account Information.  That will bring up a search screen.  Type in a “From Post Date” (you might want to use the date you mailed the check) and a “Thru Post Date.”  A Deposit Detail screen will open which will show the date and amount of any deposits made during the specified time period.  If the check has not been posted, check back every few days.  If three weeks pass without the funds being deposited in your firm’s Daily Account, contact your bank to see if the check has cleared.  If it has, call the FINRA help line at 240-386-4848.
   
   B.  Log onto IARD. Once sufficient funds are in your account, you are ready to do the transition process. After logging onto IARD, be sure that you are in the CRD System. If you are in IARD, you can get into CRD by clicking on the “Web CRD” button in the upper left-hand corner next to the “Log Off” button.
   
   C.  Find the first RA.  Under Individual, Non-Filing Info, click on IARD Transition Registration Search.  The Transition Registration Search Criteria screen will open. Type in the individual’s CRD Number, Social Security Number, or Last Name and First Name, then click on the Search button.  If a match is made, click on the underlined Name hyperlink.  If no match is made, complete the Create a New Individual section. Type the Social Security Number twice, Last Name, First Name and Birth Date. Suffix and Middle Name are optional.  Click the Create New ID button.
   
   D.  Complete and submit the Transition Registration Request. The NFI Transition Registration Request screen will open.  Type the Employment Start Date and Office of Employment Address.  Check the box if this address is a private residence.  Check the “RA” box for each state where the RA is presently registered or has a pending U-4 application.  Note: The Firm Billing Code and Street 2 are optional fields; and Country is optional if City and State are entered.  Review your information to make sure it is accurate, then Click the Submit Request button.  A message will pop up that asks “Are you really sure you want to do this?”  Click Yes.  A successful submission will result in the message “The transition registration request has been submitted successfully” appearing just below the Submit Request button.  You are now done with this individual.  Complete a Transition Registration Request for every RA on the Roster.
   
   E.  The Securities Division will review the transition.  The transition request goes into a queue for the Division to review.  The initial status is “Transition Requested.”  Division staff will check the filing against our database.  If the transition information is accurate, we will change the status to “Approved” and insert an Effective Date, which will be the date our database shows the individual was originally licensed with the firm.  If there is a problem with the Transition Registration Request, Division staff will contact you.

  5.    File electronic U-4’s for each RA on the Roster.

ELECTRONIC FORM U-4 FILING PROCEDURE

Once the individual’s Transition Registration Request has been submitted, the U-4 can be filed.  You do not need to wait for the State to complete its portion of the procedure outlined above in 4(E). 

For RA’s who have never been registered on CRD or have not been registered on CRD within the prior 30 days, file an Initial U-4.  On the CRD Main screen, under Forms, U-4 Form, click on Initial.  The Individual Search Criteria screen will open.  Type at least one of the following:  the individual’s last name and at least the first two characters of the first name, or the CRD Number, or the Social Security Number, and then click on the Search button.  The Individual Search Results screen will open, with the individual’s name.  Click on the correct Name hyperlink.  Fill in the required information (see the User’s Manual, pages 124-135 and 149-150 for detailed instructions, the Filing Instructions on the Navigation Bar on the left side of the form, or print out the instructions on the CRD Main Site Map (under Forms, Blank Form click on Blank U-4 Form, then click on the Specific Instructions link).  Click Completeness Check from the Submissions Menu or Navigation Footer.  If there are errors, click on the hyperlinks under Error Location and complete the necessary fields until all errors have been corrected.  Clink Print Preview, All Pages, File and then Print to view and print the entire form for your files.  (Note: WAC 460-24A-200(1)(t) requires you to keep a file containing copies of any documents filed with a state or federal regulatory agency or SRO.)  Click Submit Filing from the Submissions Menu or Navigation Footer when ready to submit the filing.  If the filing went through, the Filing Successfully Submitted screen will open, and then you will need to click the OK button.

For RA’s with multiple RA or RA/AG (securities salesperson) affiliations, the process is more complicated.  The User’s Manual has directions in the pages listed above, but at present it is unclear which type of filing you should choose.  NASAA is sponsoring training for the states the first weekend in May, and we expect to post more detailed instructions on our website prior to June 1.  Our main investment adviser web page is investmentadviser.htm.  Otherwise, you can call the FINRA help line.

If you have questions about the transition process or U-4 filing procedure, you can also contact Vicky Sheldon, 360-902-8775 or Nelda Shannon, 360-902-8768 at the Securities Division.

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