ARTICLE
9 March 2021

FINRA Proposes Amendments To Electronic Filing Requirements

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FINRA proposed amendments to allow firms to use electronic signatures when filing Form U4 applications for securities industry registration or transfer.
United States Finance and Banking

FINRA proposed amendments to allow firms to file uniform registration forms ("Form U4" Uniform Application for Securities Industry Registration or Transfer) with an electronic signature under FINRA Rule 1010 ("Electronic Filing Requirements for Uniform Forms"). The proposed amendments would remove references to "manual" signatures. FINRA also proposed conforming amendments to FINRA Rule 2263 ("Arbitration Disclosure to Associated Persons Signing or Acknowledging Form U-4").

FINRA described a valid electronic signature as one that "clearly identifies the signatory" and is in compliance with the Electronic Signatures in Global and National Commerce Act.

Comments on the proposed amendments must be submitted within 21 days following their publication in the Federal Register.

Primary Sources

  1. SR-FINRA-2021-003: Proposed Rule Change to Permit Firms to File a Form U4 Based on an Electronically Signed Copy of the Form

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