Is a Foreclosure a U-4 Reportable Event?
The Financial Regulatory Authority, or FINRA, maintains a system of forms disclosing the training and disciplinary records of financial representatives. If you are a registered representative, holding a Series 6, Series 7, or related license from the Securities and Exchange Commission, you must ensure that your Form U-4s are up to date and disclose all required information.
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Purpose of the U-4
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The Financial Industry Regulatory Authority uses Form U-4 as an application to become a registered representative, and to regulate the transfer of registration from one FINRA-member broker-dealer firm to another.
Contents of the U-4 Form
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The U-4 form contains personal identification data; firm data; fingerprint information; registrations; jurisdictions; residential history; employment history; disclosure of outside business activity; disclosure questions, signatures, and firm-specific sections.
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Reportable Events
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Form U-4 specifically requires you to disclose the following information: felony convictions; felony charges; charges and convictions of misdemeanors involving securities and investments, or of misdemeanors involving fraud, misrepresentation, false-statements, bribery, perjury or forgery. You must also disclose any regulatory actions taken against you by the Securities Exchange Commission or the Commodity Futures Trading Commission. You must disclose regulatory actions committed against you by state and foreign regulatory bodies, as well. You must disclose investment-related consumer complaints against you. Finally, you must disclose any bankruptcies over the past 10 years, and any unsatisfied liens or judgments against you.
Foreclosures on the U-4
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While you must report any bankruptcies within the last ten years on the Form U-4, as well as any unsatisfied liens or judgments against you, the form does not require you to disclose any foreclosures. If you had a foreclosure, but no unsatisfied liens or judgments against you currently, and your foreclosure did not involve a bankruptcy filing in the last 10 years, you do not need to report it on the U-4.
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Comments
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Besides the actual U-4 Form itself (which you used as your reference, but does not give specific instructions as to the foreclosure), what is your basis for saying it needs not be disclosed? Is this your interpretation of the U-4 language or a fact based on some authority? ~Very Curious
