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When does an Investment Adviser Representative need to update a Form U4?


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When does an Investment Adviser Representative need to update a Form U4?

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Whenever there is a material change to information that should be disclosed on the Form U4, the investment adviser representative has an obligation to update promptly that information. Typically, this means filing an amended Form U4 within 30 days of the material change. Failure to do so can lead to fines, suspensions, or even being barred from acting as an investment adviser representative.

Examples of information requiring an amendment to an investment adviser representative’s Form U4 are as follows:

  • Residential location;
  • Place of business;
  • Employment status;
  • Adding or removing jurisdictions (if applicable);
  • Other business activities; and
  • Changes in disclosure question responses causing there to be a “yes” answer
    • Criminal actions,
    • Regulatory disciplinary actions,
    • Civil judicial actions,
    • Customer complaints, arbitrations and civil litigation,
    • Terminations, and
    • Financial matters.

Not providing proper disclosure for any information on the Form U4 may result in various sanctions including, but not limited to, fines, suspensions, or even being barred from acting as an investment adviser representative.

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