Form U4 Disclosures & Fees
Overview
Agents are employees of broker-dealers or issuers who facilitate securities transactions for customers.
Like broker-dealers, agents generally must register in each state where they do business (unless an exemption or exclusion applies). The process is similar to broker-dealer registration, but a few agent-specific rules are easy to miss.
Agents use Form U4 to register with each applicable state administrator.
🔑 Definitions
| Term | Definition | Example |
|---|---|---|
| Agent | > “Any individual who represents a broker-dealer or issuer in effecting or attempting to effect purchases or sales of securities” (Uniform Securities Act definition) | An individual employed by a broker-dealer who takes customer orders to buy or sell securities |
| Enjoined | > “To legally prevent a person from engaging in a particular action or activity” | A court order barring a person from engaging in investment-related activity |
| Statutory disqualification | Condition arising from felony convictions and securities-related misdemeanor convictions within the past 10 years; if an applicant has one, the registration request would be denied | An applicant convicted of securities fraud (felony) 4 years ago is denied registration |
| Controlling affiliate | Any officer, director, partner, or person who owns a significant portion of the firm (disclosed on Form BD) | A managing partner of a broker-dealer who is registered alongside the firm without filing Form U4 |
| Compromise with creditors | Agreeing to pay less than the amount originally owed | Settling a $50,000 debt for $20,000 — must be disclosed if within the last 10 years |
🔑 Numbers & deadlines
| Item | Exact figure / deadline | Notes |
|---|---|---|
| Agent registration form | 🔑 Form U4 | Filed with each applicable state administrator |
| Broker-dealer registration form | 🔑 Form BD | Discloses controlling affiliates; they register alongside the BD |
| Employment history disclosure | 🔑 10 years | Becomes publicly available through FINRA’s BrokerCheck |
| Residential history disclosure | 🔑 5 years | — |
| Convictions that may prevent registration | 🔑 Felony convictions and securities-related misdemeanor convictions within the past 10 years | = statutory disqualification |
| Criminal events disclosure lookback | 🔑 No time limit — all relevant criminal events (including charges) must be disclosed, no matter how long ago they occurred | ⚠️ Disclosure lookback (unlimited) ≠ disqualification lookback (10 years) |
| Financial disclosures lookback | 🔑 Within the past 10 years | Bankruptcies and compromises with creditors |
| Initial registration expiration | 🔑 End of the calendar year — December 31 | Fee is not prorated |
| Renewal deadline | 🔑 Submit renewal request and fee before January 1 | To avoid a lapse |
| Filing fee | Required as part of registration | If the fee isn’t included, the registration request will be denied |
Form U4 required disclosures & obligations
Form U4 requires disclosures, and the applicant has additional obligations, including:
- Name and any nicknames
- Current address
- List of all current registrations
- Employment & residential history
- Criminal events
- Regulatory events
- Court actions
- Financial disclosures
- Payment of filing fee
| Disclosure category | What must be provided |
|---|---|
| Name & current address | Your legal name; any nicknames you use; your current residential address |
| List of all current registrations | Existing registrations in other states, listed when applying in a new state — helps the state administrator understand the scope of your activity |
| Employment & residential history | 10 years of employment history; 5 years of residential history |
| Criminal events | Felony and specified misdemeanor charges, guilty pleas, nolo contendere pleas, and convictions |
| Regulatory events | Actions by any relevant regulator (SEC, FINRA, CFTC, state/foreign regulators) |
| Court actions | Investment-related injunctions, violations, settlements, arbitrations, civil litigation |
| Financial disclosures | Bankruptcies and compromises with creditors within the past 10 years |
| Payment of filing fee | Fee must be paid; missing fee = registration request denied |
Multiple registrations rule
Even if an agent is registered in multiple states, they’re generally not allowed to be registered with more than one broker-dealer or issuer at the same time.
| Rule / Exception | Detail | Example |
|---|---|---|
| General rule | An agent may not be registered with more than one broker-dealer or issuer at the same time | — |
| Exception 1 — Affiliated firms | An agent may be registered with multiple broker-dealers or issuers if the firms are affiliated | Parsa could be registered with ABC Brokerage and XYZ Brokerage if both firms are subsidiaries of the same parent company |
| Exception 2 — Administrator-approved exception | The state administrator may grant an exception that allows registration with multiple unaffiliated broker-dealers or issuers | — |
Registering in many states is fine; registering with many unaffiliated firms is not (absent administrator approval).
Criminal events
State administrators want to know about an applicant’s criminal history because registered persons may have access to investor assets.
Form U4 asks (in part), word-for-word:
Have you ever:
- been convicted of or pled guilty or nolo contendere (“no contest”) in a domestic, foreign, or military court to any felony?
- been charged with any felony?
Have you ever:
- been convicted of or pled guilty or nolo contendere (“no contest”) in a domestic, foreign or military court to a misdemeanor involving: investments or an investment-related business or any fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
- been charged with a misdemeanor [as specified above]
| Point | Rule |
|---|---|
| Disclosure | ⚠️ All relevant criminal events (including charges) must be disclosed, no matter how long ago they occurred |
| Disqualification | Only certain convictions can prevent registration: 🔑 felony convictions and securities-related misdemeanor convictions within the past 10 years — called a statutory disqualification |
| Effect of statutory disqualification | The registration request would be denied |
| Conviction while registered | If a currently registered agent is convicted of any felony or a securities-related misdemeanor while in the industry, the state administrator would likely revoke the registration |
The text notes you’ll see more on this later when covering the powers of the state administrator.
Regulatory events
The state administrator isn’t the only regulator in the securities markets:
| Regulator | Scope |
|---|---|
| Securities and Exchange Commission (SEC) | Regulates securities markets |
| FINRA | Regulates securities markets |
| Commodity Futures Trading Commission (CFTC) | Regulates the futures markets |
| Many other regulators (domestic and foreign) | 📌 You don’t need to memorize them |
Form U4 requires you to disclose regulatory actions by any relevant regulator. The form asks, word-for-word:
Has [any domestic or foreign securities regulator, financial regulator, state or federal agency] ever:
- found you to have made a false statement or omission?
- found you to have been involved in a violation of its regulations or statutes?
- found you to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
- entered an order against you in connection with investment-related activity?
- imposed a civil money penalty on you, or ordered you to cease and desist from any activity?
- found you to have willfully violated any provision of [securities laws]?
- found you to have willfully aided, abetted, counseled, commanded, induced, or procured the violation by any person?
- found you to have failed reasonably to supervise another person subject to your supervision?
Disclosing one of these items often leads to closer review, but it doesn’t automatically prevent registration. Administrators typically evaluate these situations case by case.
Court actions
Courts can also take actions that must be disclosed on Form U4. The form asks, word-for-word:
Has any domestic or foreign court ever:
- enjoined you in connection with any investment-related activity?
- found that you were involved in a violation of any investment-related statute(s) or regulation(s)?
- dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you by a state or foreign financial regulatory authority?
Form U4 also asks, word-for-word:
Have you ever been named as a respondent/defendant in an investment-related, consumer-initiated arbitration or civil litigation which alleged that you were involved in one or more sales practice violations and which:
- is still pending, or;
- resulted in an arbitration award or civil judgment against you, regardless of amount, or;
- was settled
In general, investment-related court actions must be disclosed. Depending on the facts, a disclosure could lead to denial of the registration request.
Arbitration awards / civil judgments must be disclosed regardless of amount.
Financial disclosures
Form U4 also requires disclosure of certain financial events. It asks, word-for-word:
Within the past 10 years:
- have you made a compromise with creditors, filed a bankruptcy petition or been the subject of an involuntary bankruptcy petition?
- based upon events that occurred while you exercised control over it, has an organization made a compromise with creditors, filed a bankruptcy petition or been the subject of an involuntary bankruptcy petition?
- based upon events that occurred while you exercised control over it, has a broker or dealer been the subject of an involuntary bankruptcy petition, or had a trustee appointed, or had a direct payment procedure initiated under the Securities Investor Protection Act?
Key point: an agent must disclose bankruptcies and compromises with creditors (agreeing to pay less than the amount originally owed) that occurred within the last 10 years.
Payment of filing fee
| Rule | Detail |
|---|---|
| Fee required | A filing fee must be paid as part of the registration process |
| Missing fee | ⚠️ If the fee isn’t included, the registration request will be denied |
| Initial registration term | Lasts only until the end of the calendar year (🔑 December 31) |
| Proration | ⚠️ The fee is not prorated |
| Renewal | 🔑 Submit the renewal request and fee before January 1 to avoid a lapse |
Sidenote — Automatic registration of certain agents
Generally, broker-dealer employees who engage in securities transactions must be properly registered. The primary way to register is by filing Form U4. However, not all agents follow this process.
- Broker-dealers must disclose their controlling affiliates on Form BD (the broker-dealer registration form).
- A controlling affiliate is any officer, director, partner, or person who owns a significant portion of the firm.
- These individuals must register if they’re involved in any securities-related business, but they don’t have to submit their own registration documents.
- Instead, their information is disclosed on Form BD, and the controlling affiliate is registered alongside the broker-dealer.
- ⚠️ Because they receive effective registration at the same time as the broker-dealer, they don’t file a separate Form U4.
| Person | Registration route | Separate Form U4? |
|---|---|---|
| Ordinary agent | Files Form U4 with each applicable state administrator | Yes |
| Controlling affiliate (officer, director, partner, significant owner) | Disclosed on Form BD; registered alongside the broker-dealer | ⚠️ No |
Key points
Form U4
- Registration form for agents
- No separate Form U-4 filing for controlling affiliates
- Registered through Form BD
Agent registration disclosures
- Name and any nicknames
- Current address
- List of all current registrations
- Employment & residential history
- 10 years of employment history
- 5 years of residential history
- Criminal events
- Only applies to felonies or securities-related misdemeanors
- Any charges, guilty pleas, no contest pleas, or convictions must be disclosed
- Convictions in the past 10 years may prevent registration
- Regulatory events
- Court actions
- Financial disclosures
- Bankruptcy filings
- Compromises with creditors
- Payment of filing fee
More from Agents: Effective registration · Exclusions
Sources
Primary/official references for the material in this chapter. Every link was fetched and returned HTTP 200 on 2026-08-15.
| # | Source | Publisher |
|---|---|---|
| 1 | Uniform Securities Act 1956 with NASAA updates — the tested statute | NASAA |
| 2 | Model rule — dishonest/unethical practices of BDs and agents | NASAA |
| 3 | Achievable Series 65 — chapter 4.3.2.1 | Achievable (course text) |