Compliance Solutions for Investment Advisers

Check Those U-4s – They are Probably Outdated

Are you really at the same weight you were in 2003?

You would be positively amazed at how quickly the information on the Form U-4 can become outdated. Why? Because unlike the ADV 1, you can renew an investment adviser representative’s Form U-4 by just paying your registration renewal fees. There is no system requirement that you refile the Form U-4 every year. With the ADV 1, however, you must complete ¬†and file the Form every year. The very act of doing so forces advisers to review and update the information. The U-4 is much more along the lines of “out of sight, out of mind.” ¬†Therefore, some U-4s have not been updated for years and year.

Advisers are under a continuing obligation to update the U-4. My suggestion is to go on the IARD web site and print out the U-4 for each of your investment adviser representatives. Circulate them to the respective IARs and ask them to review and provide updated information.