FINRA Updates Judgment/Lien Disclosure Reporting Page
From the Desk of Jim Eccleston at Eccleston Law Offices:
FINRA amended the Form U4 to update the Judgment/Lien Disclosure Reporting Page (“DRP”) to add a critical question. Moving forward, reps must disclose that they learned of an unsatisfied judgment or lien.
Firms are required to report when a registered person becomes subject to an unsatisfied judgment or lien in response to Question 14M on Form U4. Further, firms must complete the corresponding Judgment/Lien DRP to provide details about this unsatisfied judgment or lien. Firms are required to report such matters not later than 30 days after learning of the facts or circumstances giving rise to the event.
Before the amendment, the Judgment/Lien DRP required only the date a judgment or lien was filed; it did not ask for information about the date that the registered representative learned of the judgment or lien. Given the work we have done for reps in defending them in FINRA proceedings against charges related to non-disclosure of judgments and liens, this new requirement adds another possible basis for FINRA to sanction reps.
The attorneys of Eccleston Law Offices represent investors and advisers nationwide in securities and employment matters. Our attorneys draw on a combined experience of nearly 50 years in delivering the highest quality legal services.
Related Attorneys: James J. Eccleston