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If the new hire is a registered person, a non-registered fingerprint individual (NRFI), or otherwise, they will receive an email that directs them to a form presenting the employee with questions regarding employment. The form will adjust for questions/needs between non-registered fingerprint individuals and individuals requiring registration(s). All human resource documents will be provided to the employee. Registrations will be processed by Nectar and Form U4s will be issued for further completion through the FinPro system to the representative, and eventually circulated for signature by applicants and/or firm principals. In the case of an NRFI, once forms are returned, NRFI forms will be filed with regulators. Non-disciplinary action reporting Form U4 will generally be completed within 15 days of the employee’s completion and submission of the form results to Nectar. Any disciplinary actions that need to be reported on a form will take longer based on the factors needed for the disclosure reporting.

The common requests with this form are those that are not automatically updated such as Outside Business Activities, residential address changes, exam requests, jurisdiction changes, and personal information changes (i.e. name changes, height, weight, hair color). All amendments will be processed and presented for signature. Amendments for disciplinary actions cannot yet be handled on this form. Non-disciplinary action reporting Form U4 amendments will generally be completed within 3-5 days of submission. Any disclosure-related updates, would need to take place through the FinPro system and also be circulated for signature by both the representative and the appropriate supervisor.

Any final Form U5 will also be emailed to the email address provided by you on the termination form. Please ensure it is a private email address, as including firm-related email addresses for the terminating employee may not lead to the proper delivery of the Form U5, per regulations. Non-disciplinary action reporting Form U5s will generally be completed within 15 days of the employee’s termination date. Any disciplinary action reporting will need to be addressed with disclosure reporting pages and will take longer.

Timing of processing is generally completed within 15 days from the receipt of the notice from the registered person. Please ensure that the representative recognizes that they may not proceed unless they have received approval on their written notice. This will be explained in the email to them as well as the form, but reminders are always appreciated. The firm will need to make a determination whether this is indeed a private securities transaction or otherwise an outside business activity, and will also need to assess it for conflicts of interest and whether there are any imposed restrictions on the activity.

Disclosure of outside business activities by a registered person may sometimes be confused when the actions are actually private securities transactions. The completion of this form by a representative will need to be assessed for this and whether it is classified appropriately, and whether additional disclosures are necessary. What will also be assessed is whether the Outside Business Activity should be included on the Form U4 as an amendment. This will generally be done within 15 days of submission, which should be done prior to the business activity being conducted.