November 14, 2009 is the Deadline to File Updated Disclosure Information on Form U4s

The Form U4 was amended to include additional disclosure questions. All associated persons of broker-dealers and certain investment adviser representatives must file an updated Form U4 answering the additional disclosure questions. Form U4s must be updated by November 14, 2009. States oversee their own Form U4 filing requirements for registered investment adviser representatives and Form U4 compliance requirements should be reviewed on a state-by-state basis. To make the revised Form U4 filing process less onerous for broker-dealers, FINRA Rule 1010 permits broker-dealers to file amendments related to the new Form U4 disclosure section without obtaining the manual signature of associated persons, subject to certain conditions. Broker-dealers must use reasonable efforts to (1) provide the associated person with a copy of the amended disclosure information and (2) obtain the associated person's written acknowledgement (which may be electronic) that the information has been received and reviewed. Such written acknowledgments should be retained in order to satisfy the record retention requirements set forth under Rule 17a-4 of the Securities Exchange Act of 1934.

If you would like additional information, please do not hesitate to contact Daniel G. Viola at (212) 573-8038, dviola@sglawyers.com.

Cheryl Spratt