Reporting Disclosure Events

Registered broker-dealers must report specified disclosure events on Forms BD, U4 and U5 within prescribed timeframes.  Firms also must report to FINRA certain events, known as the "Ten Disclosure Events," pursuant to NASD Rule 3070.  Failure to make timely and accurate disclosures can result in significant adverse consequences.  Thus, firms should be aware of the triggers and timeframes for regulatory disclosure and the need to implement effective systems and procedures around these requirements.

Articles IV and V of FINRA's By-Laws make clear that a broker-dealer is under a continuing obligation to amend Forms BD, U4 and U5 whenever there is a change to the information reported on the Forms.¹  In general, a firm must amend a Form within thirty days from the date it first learns of the facts or circumstances giving rise to the reporting obligation.²  Form BD requires disclosure of, among other things, regulatory and civil judicial actions pertaining to the firm and