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Broker Dealer Guide

Succession and Mass Transfers

When firms are combined by merger or acquisition, FINRA will determine how the CRD transactions are handled. In a situation where the surviving firm that results from the transaction maintains the old CRD number of its counterpart, the firm need only file its normal Form BD amendments via CRD. There are no state fees involved and nothing need be filed regarding agents or branches.

When one firm succeeds to the business of another firm and the new firm is not currently registered as a broker-dealer with FINRA, a new CRD number will be issued for the new firm. The firm will be instructed by FINRA regarding what Form BD filings to make. Fees due for the firm will be deducted from the firm's CRD account.

In cases where agents and branches of an old firm must be moved to a firm with a different CRD number, FINRA will prepare a Mass Transfer of agents. FINRA sets the date the transfer will take place based on the firm's request. The firm will advise the CRD which agents will transfer in each jurisdiction. The Division receives a notice via CRD that a Mass Transfer will be taking place and a list of agents and branches to be transferred.

The Division will review the list of agents to determine if any with disclosures or that are currently under investigation by the Division should be blocked. Those agents will not be moved via the Mass Transfer and will need to make a separate U4 filing for registration in Wisconsin. Those agents will likely need to supply specific information requested by the Division before an approval determination will be made. The firm will be charged the $80 for each agent and branch on the Mass Transfer list, including those agents transferred in a PENDING status. Mass Transfer fees are deducted from the firm's CRD account.

Any discrepancies in the agents transferred or not transferred should be directed to the CRD.