14.2 Registration & Post-Registration
IAR Registration & Post-Registration Requirements
Once qualified, IARs must complete registration and maintain ongoing compliance with various requirements, including continuing education.
Form U4 Registration
The Uniform Application for Securities Industry Registration or Transfer (Form U4) is the registration document for IARs.
Required Information on Form U4
Personal Information: Name, SSN, date of birth, residential addresses (5 years)
Employment History: Complete history for past 10 years
Education: Schools attended, degrees obtained
Disclosure Questions: Criminal, regulatory, civil, financial, termination history
Fingerprints: Required in most states
Exam Information: Exams passed or designations held
Disclosure Questions
Form U4 requires disclosure of:
Criminal: Felony charges/convictions, certain misdemeanors
Regulatory: Disciplinary actions, investigations, sanctions
Civil: Investment-related lawsuits, arbitrations
Customer Complaints: Written complaints alleging sales practice violations
Terminations: For cause, permitted to resign, allegations
Financial: Bankruptcies, liens, judgments, bonding failures
Filing Through CRD/IARD
CRD: Central Registration Depository—manages registrations
IARD: Investment Adviser Registration Depository—IA firm filings
Electronic Filing: All Form U4 filings are electronic
State Fees: Vary by state, paid through IARD
Amendment Requirements
Timing for Form U4 Amendments
Disclosure Events: Within 30 days
Criminal Charges: Within 10 days
Name/Address Changes: Within 30 days
Material Changes: Promptly (generally 30 days)
On the Exam: Criminal charges (not just convictions) must be disclosed within 10 days—a shorter timeframe than most other amendments.
Continuing Education Requirements
NASAA IAR CE Model Rule
Most states have adopted continuing education requirements:
Total Credits: 12 credits annually
Products & Practice: 6 credits required
Ethics & Professional Responsibility: 6 credits required
Credit Definition: 1 credit = at least 50 minutes of instruction
Annual Deadline: December 31
CE Content Areas
Products & Practice (6 credits):
- Investment products and strategies
- Portfolio management techniques
- Regulatory compliance
- Industry standards and best practices
Ethics & Professional Responsibility (6 credits):
- Fiduciary duties
- Conflicts of interest
- Professional standards
- At least 50% must cover ethical responsibility
First-Year Exception
New Registration: No CE required until January 1 of following year
Example: IAR registers February 2026 → CE begins January 1, 2027
Non-Compliance Consequences
CE Not Completed by Dec 31: Status set to "CE Inactive"
CE Inactive Status: Appears on IAPD and BrokerCheck
Continued Non-Compliance: Unable to renew registration
Extended Non-Compliance: Registration termination
Termination and Form U5
Form U5 Requirements
Filing Deadline: Within 30 days of termination
Filed By: The investment adviser firm
Contents: Reason for termination, disclosure updates
Public Record: Follows individual's registration record
Reasons for Termination
Voluntary: IAR resigns on own accord
Permitted to Resign: Resigned while under investigation
Discharged: Terminated by firm
Other: Business reasons, restructuring
Exam Validity After Termination
Within 2 Years: Can re-register without re-taking exam
After 2 Years: Must re-take qualifying exam
State Variations: Some states have different rules
Supervision Requirements
Adviser Responsibilities
Written Procedures: Establish supervisory policies
Designated Supervisor: Assign supervision responsibility
Transaction Review: Review IAR trading activity
Correspondence Review: Monitor client communications
Training: Ongoing compliance education
Annual Compliance Review: Evaluate effectiveness of procedures
IAR Responsibilities
Follow Policies: Adhere to firm procedures
Accurate Records: Maintain proper documentation
Disclosure: Report required information
Act Within Authority: Stay within granted powers
Report Issues: Escalate problems to supervisor
Key Takeaways
1. Form U4 requires 10-year employment history and 5-year residential history
2. Criminal charges must be reported within 10 days; most other changes within 30 days
3. IAR CE requires 12 credits annually: 6 Products & Practice + 6 Ethics
4. Form U5 must be filed within 30 days of termination
5. Exam validity: 2 years from termination date
Frequently Asked Questions
Q: The annual continuing education requirement for IARs under the NASAA model rule is:
A: 12 credits: 6 in Products & Practice and 6 in Ethics. The NASAA IAR CE model rule requires 12 credits annually, split evenly between 6 credits of Products & Practice and 6 credits of Ethics & Professional Responsibility. The split is mandatory—credits cannot be substituted between categories.
Q: When an IAR is terminated, the investment adviser must file Form U5:
A: Within 30 days. Form U5 (Uniform Termination Notice) must be filed within 30 days of an IAR's termination. The form includes the reason for termination and becomes part of the individual's public record.
Q: An IAR who has been terminated for 18 months wishes to re-register. They must:
A: Re-register without re-taking the exam (exam valid for 2 years). Exam validity continues for 2 years from the termination date. Since 18 months is within the 2-year window, the individual can re-register without re-taking the qualifying exam.