Notice of Request for Public and Internal Comment on Proposed Changes to the Judgment-Lien Disclosure Reporting Page on Form U4
The Board of Directors of the North American Securities Administrators Association, Inc. (NASAA) has authorized the release for internal and public comment for proposed changes to the Judgment/Lien Disclosure Reporting Page of the Uniform Application for Securities Industry Registration or Transfer (Form U4).
Background and Summary
Representatives of broker-dealers, investment advisers, or issuers of securities must use Form U4 to become registered in the appropriate jurisdictions or with self-regulatory organizations. The Judgment/Lien DRP is used for disclosure of details in connection with affirmative response(s) to Question(s) 14M on Form U4, which elicits information regarding the existence of unsatisfied judgments or liens against the individual Form U4 filer. NASAA’s CRD/IARD Steering Committee and NASAA’s CRD/IARD Forms and Process Committee propose to expand the information requested in Item 4 of the Judgment/Lien DRP, as detailed below.
Currently Item 4 of the Form U4 Judgment/Lien DRP is designed to elicit information regarding the date a judgment or lien is filed, which may not be the same date as the individual making this disclosure learnt of the event. Therefore, the proposed change would add a second question to Item 4. requesting information on the date an individual learned of the judgment/lien event. The proposed changed would align the disclosure of a judgment or lien more closely to the process by which an individual learns this information.
The comment period will remain open to August 19, 2013. To facilitate consideration of comments, please submit comments to the following individuals: Melanie Senter Lubin (firstname.lastname@example.org), Chair of CRD/IARD Steering Committee, Pamela Epting, Chair of CRD/IARD Forms and Process Committee (email@example.com), and Joseph Brady (firstname.lastname@example.org) and A.Valerie Mirko (email@example.com), NASAA Legal Department. We encourage, but do not require, comments to be submitted by e-mail. Hard copy comments can be submitted to the address below. We also welcome any general comments regarding the Judgment/Lien DRP orForm U4.
NASAA Legal Department
Joseph Brady, General Counsel
A.Valerie Mirko, Associate General Counsel
750 First Street N.E., Suite 1140
Washington, DC 20002