In April 2014, FINRA announced it would conduct a review of public records available for the entire population of approximately 630,000 active registered representatives (RRs) for financial disclosures that may not have been reported and for criminal disclosures that may not have been reported by RRs who have not been fingerprinted within the last five years. FINRA has been working with a public records data aggregator to facilitate this review and FINRA then compared information obtained with information reported to the CRD system to determine whether there were possible unreported disclosures.
As a result, a large number of FINRA member firms and RRs are now scrambling to update financial disclosures of RRs going back for years. It appears to some that FINRA has hit the jackpot, as the late fees are significant. Based on the filing and late fees, the cost can be up to $1,685 for a disclosure filed over 30 days late, and since most disclosures go back years, the ultimate number will be significant.
In any event, Click here to read FINRA’s update regarding the CRD Public Records Validation Initiative.