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Winthrop & Co.
Market Insights
GuideFiled September 28, 20266 min read

Form U4 vs Form U5: What Each Form Does, and How They Work Together When You Move

Form U4 registers a financial professional with a firm and carries their disclosure history; Form U5 ends that registration and records why. Who files each, the 30-day deadlines, the disclosure questions, what reaches BrokerCheck and what does not, the fees, and how the two forms hand an advisor from one firm to the next.

Filed by Tyler Noe

GuideForm U4 vs Form U5: What Each Does and How They Connect (2026)

The short answer: Form U4 and Form U5 are the two ends of a securities registration. The U4, the Uniform Application for Securities Industry Registration or Transfer, registers an individual with a broker-dealer or investment adviser and carries their disclosure history. The U5, the Uniform Termination Notice, ends that registration and records why the person left. The firm files both, and each runs on a 30-day deadline.

When an advisor changes firms, the two forms meet: the old firm files the U5, the new firm files the U4, and the dates on them decide whether the advisor's registrations and exams carry over.

The two forms, side by side

Form U4Form U5
Full nameUniform Application for Securities Industry Registration or TransferUniform Termination Notice for Securities Industry Registration
What it doesRegisters the individual with the firm and the relevant regulatorsEnds the registration and records the reason for leaving
Who files itThe hiring firm, through FINRA's systemsThe departing firm
DeadlineAmendments within 30 days of learning the facts; 10 days for a statutory disqualificationWithin 30 days of termination, with a copy to the individual at the same time
What it disclosesCriminal, regulatory, civil, customer complaint, termination and financial eventsReason for termination, internal reviews, investigations and related events
Who it coversRegistered representatives and investment adviser representativesRegistered representatives and investment adviser representatives
Initial filing fee$125$50

FINRA, NASAA and the state securities regulators developed the two forms together, and the SEC approved them. Both are filed electronically: a firm's authorized users submit them through FINRA Gateway, and investment adviser representatives are registered with the states through a U4 filed through CRD and IARD.

What Form U4 asks

Most of the U4 is identity and history: personal details, fingerprints, the registrations sought, and ten years of residential and employment history. The part that matters most is Question 14, the disclosure questions:

  • Criminal (14A and 14B): felony and certain misdemeanor charges and convictions.
  • Regulatory (14C to 14G): actions by the SEC, the CFTC, other federal and state regulators and self-regulatory organizations, professional license matters, and pending proceedings.
  • Civil (14H): certain investment-related civil actions.
  • Customer complaints and arbitration (14I).
  • Terminations (14J): being discharged or permitted to resign after allegations of certain misconduct.
  • Financial (14K to 14M): a bankruptcy or compromise with creditors in the past 10 years, a denied or revoked bond, and unsatisfied judgments or liens.

FINRA's interpretive guidance closes the obvious escape routes. A customer complaint is reported even if the customer later withdraws it, a pardoned conviction is still reported, and a judgment or lien stays reportable within 30 days even if it has since been paid. Filing incomplete or inaccurate information that is misleading violates FINRA Rule 1122.

By signing, the individual also agrees to keep the form current through timely amendments and to arbitrate disputes with the firm, which is why employment disputes in this industry usually end up in FINRA arbitration instead of court.

What Form U5 records

The U5 is shorter. It records the termination date, the reason for termination (voluntary, discharged, permitted to resign, deceased or other, with an explanation required for the discharged, permitted-to-resign and other categories) and a set of disclosure questions: whether the individual was under internal review for fraud or wrongful taking of property at termination, whether they were the subject of an investigation, and whether they were discharged or permitted to resign after allegations of certain misconduct. The individual may add their own summary of up to 4,000 characters to some answers.

The firm's obligation continues after the filing: it must amend the U5 within 30 days of learning new facts, and FINRA's guidance is plain that this obligation does not lapse. What an advisor can do when the U5 language itself is the problem, including amendment, arbitration and expungement, is its own subject, covered in what a terminated advisor actually does next.

What BrokerCheck shows from each

BrokerCheck publishes information from the most recently filed U4 and U5, with specific exceptions under FINRA Rule 8312:

Released on BrokerCheck?
U4 employment history and registrationsYes
U4 disclosure eventsYes
U5 Reason for Termination sectionNo, withheld under Rule 8312
U5 internal review disclosureNo, withheld under Rule 8312
Other U5 disclosure eventsYes, three business days after FINRA processes the filing
Social Security number, residential history, physical descriptionNo

Former representatives stay on BrokerCheck for ten years after they were last associated with a firm, and certain events, including final regulatory actions, remain available permanently. An individual can add a comment to their own disclosures, and a person no longer registered can submit a broker comment through FINRA.

How the two forms connect when you move

A move is a U5 and a U4 in sequence, and the gap between them matters:

  1. The old firm files the U5 within 30 days of the resignation date, and gives you a copy. The termination date on it is the date regulators use to decide whether you must requalify by exam.
  2. The new firm files the U4. If you were registered within the prior 30 days, the U4 lets you request temporary registration while the new registration is processed, but you may not conduct business that requires registration until the CRD or IARD system confirms it.
  3. The clock starts at the termination date. Stay unregistered for two years and the representative exams generally have to be retaken, and the SIE after four years. The Maintaining Qualifications Program extends the window to five years for people who were registered at least a year and complete annual continuing education.

Advisors moving from a broker-dealer to an RIA meet this clock directly, because dropping the broker-dealer registration is itself a U5. Lapsing your Series 7 when you go RIA and the dually registered advisor cover that choice, and the transition checklist puts the filings in order with everything else in a move.

The fees

FINRA's fee schedule charges the firm:

FilingFee
Initial Form U4$125
Initial Form U5$50
Additional processing for any U4 or U5 reporting a disclosure event$155
Late disclosure$100 on the first day, then $25 a day, up to $1,575
Late initial U5 (after 30 days)$100

How many people this touches

FINRA counted 639,723 registered representatives at the end of 2025. Its 2026 Industry Snapshot estimates that 41,570 individuals left FINRA registration in 2025 and 46,795 entered, and every one of those departures and arrivals ran through these two forms.

Advisors planning a move who want the paperwork, the timing and the offers handled with discretion are welcome to request an introduction.

Sources (16)

Frequently asked

What is the difference between Form U4 and Form U5?
Form U4 registers an individual with a broker-dealer or investment adviser and records their background and disclosure history. Form U5 terminates that registration and records the reason the individual left. When an advisor changes firms, the old firm files a U5 and the new firm files a U4.
Who files Form U4, the advisor or the firm?
The firm files it electronically through FINRA Gateway, using the information the individual provides and signs. The individual agrees on the form to keep it current by causing amendments to be filed on a timely basis. Investment adviser representatives are registered with the states through a Form U4 filed through CRD and IARD.
How long does a firm have to update Form U4?
Thirty days. FINRA's By-Laws require amendments no later than 30 days after learning of the facts or circumstances giving rise to them, and within ten days for a statutory disqualification. A reportable judgment or lien must still be reported even if it has since been paid.
How long does a firm have to file Form U5?
No later than 30 days after the termination, and the firm must give the individual a copy of the U5 as filed at the same time. FINRA charges the firm a $100 late fee if the initial U5 is not filed within 30 days. The firm's duty to amend the U5 when it learns new facts does not lapse.
Does the reason for termination on Form U5 show on BrokerCheck?
The Reason for Termination section itself is not released. FINRA Rule 8312 withholds that section and the U5's internal review disclosure. Other disclosure events reported on the U5, such as a termination after allegations of certain misconduct, are released three business days after FINRA processes the filing.
How long does a former broker stay on BrokerCheck?
FINRA releases information on individuals who were associated with a BrokerCheck firm within the preceding ten years. Certain events, including final regulatory actions, remain available permanently.
How long can I be out of the industry before I have to retake my exams?
Generally two years from the termination date on the U5, after which representative qualification exams must be retaken; the SIE lapses after four years. The Maintaining Qualifications Program lets a person who was registered for at least a year keep their qualifications for up to five years by completing annual continuing education.
What does it cost to file Form U4 and Form U5?
Under FINRA's fee schedule, $125 for each initial Form U4, $50 for each initial Form U5, and $155 for the additional processing of any U4 or U5 filing that reports a disclosure event. Late disclosure costs $100 on the first day and $25 a day after, up to $1,575, and a late U5 costs $100.

Filed

September 28, 2026

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