The IA Comment Process permits eligible individuals to provide an update or additional context to information that is disclosed on their Individual Report in IAPD.
On this page you will find information on eligibility, the IA Comment Request Form, and instructions on how to submit a comment.
Guidelines for IA Comments on IAPD
Who Can Submit an IA Comment?
An individual who currently is not registered as an Investment Adviser Representative (IAR), but for whom an Investment Adviser Public Disclosure (IAPD) report is available, may submit a request to add or revise an IA Comment that provides an update or adds context to information disclosed through IAPD. Individuals who currently are IAR-registered and wish to provide an update or add context to information disclosed through IAPD may do so by filing an amended Form U4 via Web CRD.
What Are the Eligibility Criteria for an IA Comment?
Comments must meet IAPD publication standards. FINRA, in consultation with state regulators, reserves the right to reject or redact a comment that it deems to be inappropriate or does not adhere to the following criteria:
- The individual submitting the request is not currently IAR-registered.
- The comment pertains to the IAPD report of the individual submitting the request.
- The comment addresses information disclosed through IAPD.
- The comment is written in the first person narrative point of view to minimize any potential confusion on the part of the reader.
- The comment does not contain confidential or identifying information about customers or others; offensive or potentially defamatory language; or information that raises significant identity theft, personal safety or privacy concerns.
How Do I Submit an IA Comment?
An individual may submit an IA Comment request via mail or email by using the contact information below. Please include the following:
- A completed, signed and notarized IA Comment Request Form. The form is “fillable,” and this means that you may type the necessary information directly into the displayed fields. Save the applicable form to your local drive on your own computer before inputting any information.
- The section(s) of the individual’s IAPD report for which a comment is requested (highlighting or circling the specific section is sufficient).
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Email: |
Mailing Address: |
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Note: There is no electronic signature option when submitting the completed forms electronically. If you submit your Broker Comment via email, please print, notarize and sign/date the hardcopy form. The form must then be attached as a scanned .pdf image to an email. |
Registration and Disclosure/Regulatory Services and Operations |
FINRA will not accept requests sent via facsimile.
What Happens After the Review?
IA Comments that meet criteria discussed herein generally will be posted to IAPD within thirty business days of receipt. The IA Comment will be displayed in IAPD as long as the report is available to the public.
What If I Want to Change the IA Comment or If I Register with a Firm?
An individual may replace or delete a previously submitted comment by submitting another IA Comment Request Form.
If an individual becomes IAR-registered, a previously posted IA Comment will no longer display through IAPD and the individual may provide any updated information that was the subject of the IA Comment via a Form U4.
Questions?
Questions may be directed to the IARD Call Center at (240) 386-4848.