Following are FAQ about FINRA registration and qualification requirements. Click on the links below to view all sections of the FAQ.
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- Exams
- Foreign Associates
- Registration
Exams
1. What exam is required to trade certificates of deposit (CDs)?
An individual associated with a firm must register with FINRA as either a General Securities Representative (Series 7) or a Corporate Securities Representative (Series 62) to effect transactions in CDs that are structured as securities.
2. What registration is required for an individual associated with a firm who is engaged in the solicitation, purchase or sale of shares of an interval fund?
An individual associated with a firm may engage in the solicitation, purchase or sale of shares of interval funds if the individual is registered with FINRA as a General Securities Representative (Series 7). Alternatively, because interval fund shares are redeemable securities of a company registered pursuant to the Investment Company Act, an individual associated with a firm may engage in such activities if the individual is registered with FINRA as an Investment Company and Variable Contracts Products Representative (Series 6) .
Note: A registered closed-end investment company that periodically repurchases common stock of which it is the issuer from the fund's shareholders pursuant to Investment Company Act Rule 23c-3 is known as an interval fund.
3. If I pass a FINRA exam, do I still have to take the Series 63 exam?
Most states require the Uniform Securities Agent State Law Exam (Series 63) for individuals who will transact a securities business. This qualification requirement adds onto FINRA's requirements.
4. Is there a prerequisite requirement for the Municipal Fund Securities Principal Exam (Series 51)?
An individual seeking to qualify as a Municipal Fund Securities Principal must be qualified as a General Securities Principal (Series 24) or Investment Company/Variable Contracts Principal (Series 26).
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Foreign Associates
FINRA has retired the Foreign Associate registration. An individual currently registered as a Foreign Associate may continue to maintain that registration. However, if the individual subsequently terminates their Foreign Associate registration with FINRA, they will not be able to re-register as a Foreign Associate. For more information, refer toRegulatory Notice 17-30.
1. Who is eligible for registration as a Foreign Associate? What functions is an individual holding a Foreign Associate registration permitted to perform at a firm?
An individual holding a Foreign Associate registration who is not a citizen, national or resident of the U.S. or any of its territories or possessions who does not engage in securities activities with or for any resident, citizen or national of the U.S is permitted to engage in securities activities for the firm outside the jurisdiction of the U.S. only.
2. In what capacity is an individual registered as a Foreign Associate permitted to act on behalf of a firm?
An individual holding a Foreign Associate registration is permitted to act in any registered capacity on behalf of the firm in a manner that is consistent with this designation. This can include acting as a trader or being the registered person responsible for servicing accounts of a foreign national.
3. In what capacity is a foreign finder permitted to act on behalf of a firm?
Foreign finders are not considered associated persons of a firm. The sole involvement of a foreign finder is the initial referral of non-U.S. customers to the firm.
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Registration
1. Who must register as a representative?
Anyone actively involved in a firm's investment banking or securities business must be registered as a representative with FINRA. Their duties may include supervision, solicitation or training of persons associated with the member.
[FINRA Registration Categories Rule 1220(b)(1) - Definition of Representative]
2. Who must register as a principal?
Persons associated with a firm who are actively engaged in the management of the firm's investment banking or securities business, including supervision, solicitation, conduct of business, or the training of persons associated with a member for any of these functions are designated as principals. Such persons shall include:
- sole proprietors,
- officers,
- partners,
- managers of offices of supervisory jurisdiction, and
- directors of corporations.
[FINRA Registration Categories Rule 1220(a)(1) - Definition of Principal]
3. What are the registration and qualification requirements for a FINRA-registered firm's chief compliance officer (CCO)?
The CCO must be designated on Schedule A of a firm's Form BD and must hold the Compliance Officer (CR) registration. To obtain a CR registration, individuals are required to 1) pass the Compliance Official Exam (Series 14) or 2) pass theSIE, the General Securities Representative Exam (Series 7) and the General Securities Principal Exam (Series 24).
If the firm's activities are limited to particular areas of the investment banking or securities business, the CCO may apply for a limited principal registration, such as the Limited Principal Investment Company and Variable Contracts Products (Series 26), Limited Principal Direct Participation Programs (Series 39), and Government Securities Principal.
Individuals registering as compliance officers on or after October 1, 2018, are required to 1) pass the Compliance Official (Series 14) Exam; or 2) pass theSIE, the General Securities Representative (Series 7) Exam and the General Securities Principal (Series 24) Exam.
For more information, refer toRegulatory Notice 17-30.
4. Am I permitted to solicit customer accounts once my firm submits the Form U4 for me to FINRA but before my registration becomes effective?
No, you are not permitted to perform registered representative functions until your registration becomes approved with all regulatory organizations and state securities commissions. You are permitted to work in other areas at the firm if the tasks do not require registration.
5. Am I permitted to continue servicing my customers' accounts before my re-registration becomes effective with my new employer member?
No, you are not permitted to transact any securities business until your registration with your new firm is approved.
6. If a friend who is not registered with FINRA refers clients to me, am I permitted to pay thema commission for these referrals?
No, you are not permitted toshare commissions generated from securities transactions with non-registered individuals.
7. Am I permitted to maintain an active registration with two FINRA-registered firms concurrently?
FINRA does not prohibit an individual from maintaining concurrent registrations, but both firms must agree to this arrangement. You must be sure that this dual affiliation does not violate the registration requirements of other self-regulatory organizations (SROs) or state securities commissions.
8. How long will my qualification exam(s) be valid after I end my affiliation with a FINRA-registered firm?
YourSIEexam is valid up to four years. All other exams are valid for two years after your registration has been terminated. (Note: The qualification termination period is calculated from the employment end date with the prior employer or from the continuing education inactive date, whichever is earlier.)
Effective March 15, 2022, the Maintaining Qualifications Program (MQP) provides eligible individuals who elect to enroll in the MQP a maximum of five years in which to re-register with a member firm without having to requalify by exam or having to obtain an exam waiver. To determine if you meet the eligibility conditions, visit the MQP page.
[FINRA Registration Requirements 1210.08 - Lapse of Registration and Expiration of SIE; FINRA Rule 1240(c) - Continuing Education Program for Persons Maintaining Their Qualification Following the Termination of a Registration Category]
9. I am currently registered as a General Securities Representative (Series 7). I want to join a direct participation program (DPP) firm. Will I lose my General Securities status if this new firm registers me as a DPP representative?
If you do not re-register as a General Securities Representative (GS) within two years of the date from when you were last registered, the GS qualification will lapse. You must then retest to function in the GS capacity in the future.
[FINRA Registration Requirements 1210; FINRA Registration Categories Rule 1220(b) - Definition of Representative and Representative Registration Categories]
10. I held a General Securities Principal (Series 24) registration. Now I am with a new firm and will only register as a General Securities Representative (Series 7). Will I lose my principal status?
If you do not re-register as a principal within two years of your last principal registration, the principal qualification will lapse. You must then retest to function in that capacity in the future.
[FINRA Registration Requirements Rule 1210; FINRA Registration Requirements 1210.08 - Lapse of Registration and Expiration of SIE]
11. I am joining a FINRA-registered firm as a consultant to hold public seminars promoting its products and services. Should I register since this firm does not technically employ me?
The activity described requires registration as a representative or principal. Your employment status does not affect your involvement in the firm's investment banking or securities business.
[FINRA Registration Requirements Rule 1210; FINRA Registration Categories Rule 1220]
12. I am an independent contractor (not an employee) of a large insurance company. I refer potential customers to this firm. Should I become registered?
Under FINRA rules, job functions determine the registration requirement. Therefore, you must be registered if you solicit customer accounts for a firm regardless of the terms of your contract with this firm.
[2018 FINRA Registration Requirements Rule 1210; FINRA Registration Categories Rule 1220]
13. Is a firm permitted to hire unregistered individuals whose sole function will be to cold call potential customers?
FINRA-registered firms are permitted to employ unregistered individuals for the purposes of:
- extending invitations to firm-sponsored events at which presentations and account or order solicitation will be conducted by appropriately registered personnel;
- inquiring whether the prospective customer wants to discuss investments with a registered person; and
- determining whether the prospective customer wants to receive investment literature from the firm.
The firms employing unregistered persons to perform these functions must be sure these employees do not discuss general or specific investment products or services offered by the firm; prequalify prospective customers as to financial status, investment history and objectives; or solicit new accounts or orders.
[FINRA Registration Categories Rule 1220(a) - Definition of Principal and Principal Registration Categories; FINRA Registration Categories Rule 1220(b) - Definition of Representative and Representative Registration Categories]
14. While registered with firm "A," am I permitted to sell limited partnership interests for nonmember firm "B" in a private placement?
To participate in a private securities transaction, you must provide your firm written notice describing the proposed transaction and your role in this activity. You must also notify your firm whether you have received or will receive selling compensation in connection with the transaction. The firm must provide you with a written statement advising whether it approves or disapproves your participation in the proposed transaction. If the firm allows such activity, the firm must record the transaction(s) on its books and records. The firm must also supervise your participation in the transaction.
[FINRA Rule 3280 - Private Securities Transactions of an Associated Person]
15. A firm wants to employ me to sell securities only to institutions. I will not have any retail customers. Do I have to register with FINRA?
Yes. Under FINRA rules, anyone associated with a firm who engages in the investment banking or securities business for the firm must register. The rules do not distinguish between retail and institutional securities customers.
[FINRA Registration Requirements Rule 1210; FINRA Registration Categories Rule 1220]
16. Do I need to register if I will only be selling exempt securities?
Yes. The terms "exempt securities" and "exempt transactions" mean these particular securities or transactions (private placements or intrastate offerings) are exempt from the filing requirements of the Securities Act of 1933. Anyone dealing with exempt securities and/or exempt transactions, however, must register.
[Securities Act of 1933 Sections 3 and 4]
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