What is Form U5?
Form U5, the Uniform Termination Notice for Securities Industry Registration, is the form a broker-dealer files through FINRA's Central Registration Depository (CRD) to end an individual's registration with FINRA, other self-regulatory organizations and the states. It is the counterpart to Form U4, which registers an individual with a firm.
A U5 can be a full termination, when the person's employment ends, or a partial termination of specific registrations. For a full termination, the form records the reason the person left and answers a series of disclosure questions in Section 7 about investigations, internal reviews, customer complaints and the circumstances of the departure. Regulators, other firms and, through BrokerCheck, the public rely on that information.
When must a firm file a U5, and does the advisor get a copy?
FINRA's By-Laws (Article V, Section 3) require a member firm to file an initial Form U5 within 30 days of terminating an associated person's registration, as FINRA described in Regulatory Notice 25-09. The same provision requires the firm to give the individual a copy of the initial U5 and of any amended U5.
FINRA said in Regulatory Notice 25-09 that, as of Nov. 3, 2025, firms can deliver those copies of Forms U4 and U5 to individuals electronically through its FinPro Gateway system. FINRA has warned, in Regulatory Notice 10-39, that firms may face administrative and civil penalties for failing to file complete and accurate U5 information on time, and NASD Notice to Members 04-09 noted that late disclosure filings carry a daily CRD late fee.
What are the termination reasons on a Form U5?
For a full termination, the firm must choose one of five reasons from a drop-down menu: Voluntary, Discharged, Permitted to Resign, Deceased or Other, according to FINRA's 2023 webinar on terminations and internal reviews.
According to the Form U5 instructions, if the reason is Permitted to Resign, Discharged or Other, the firm must add a narrative explanation. FINRA's Disclosure Review staff review those explanations and can send a firm a letter requiring more disclosure or clarification, and FINRA has said explanations must carry enough detail for a reasonable person to understand what happened.
A Voluntary termination does not require an explanation. That is one reason the choice between Voluntary and Permitted to Resign, and the wording of any explanation, is often contested when an advisor leaves under a cloud.
What is Question 7F, and how do internal reviews get disclosed?
Question 7F asks whether the individual voluntarily resigned, was discharged or was permitted to resign after allegations accusing them of violating investment-related statutes, rules or industry standards of conduct, of fraud or wrongful taking of property, or of failure to supervise in connection with investment-related rules. FINRA's 2023 webinar notes Form U4 has a parallel question, 14J.
FINRA said in Regulatory Notice 10-39 that a firm must answer 7F yes even if the firm itself did not make the allegations, giving the example of fraud allegations raised by an affiliate. FINRA also said each U5 question stands on its own, so the reason chosen for termination does not substitute for a required 7F answer, and firms may not parse the questions to avoid answering affirmatively.
Section 7 separately asks whether the person is currently, or was at termination, under internal review for fraud, wrongful taking of property or violating investment-related rules. Firms have a continuing obligation to update Section 7 disclosures until a matter reaches final disposition, according to FINRA.
When must a Form U5 be amended?
Under the same By-Laws provision, a firm must file an amended U5 within 30 days after it learns of facts or circumstances that make information on the form inaccurate or incomplete, according to FINRA Regulatory Notice 25-09. NASD Notice to Members 04-09 explained that the 30-day clock runs from when the firm learns of the triggering facts.
In practice, this means a U5 can change after an advisor has left. A customer complaint, regulatory inquiry or internal review that surfaces later can lead the former firm to file an amendment, and the individual must receive a copy of it.
How does U5 information appear on BrokerCheck?
FINRA Rule 8312 governs what FINRA releases through BrokerCheck, its free public tool for researching brokers. Investors use the U5 information shown there, which is why termination disclosures matter to an advisor's ability to attract clients and change firms, as FINRA has noted.
Rule 8312 originally delayed release of Form U5 disclosure information by 15 days so the individual could respond, either on a Form U4 or with a comment submitted to FINRA. According to FINRA Regulatory Notice 15-49, the SEC approved shortening that waiting period to three business days, effective Dec. 12, 2015; the amended rule excludes internal review disclosures from the delay.
BrokerCheck's dispute process is meant for purely factual errors, not subjective or interpretive items such as the reason for a termination, according to law firm Scarinci Hollenbeck. Removing that kind of information requires expungement.
How can an advisor challenge a U5 through defamation or expungement?
Disputes over U5 language between an advisor and a former firm are generally heard in FINRA arbitration under its Industry Code. Law firm Littler has reported that Form U5 defamation claims are on the rise. The rules differ by jurisdiction: New York's highest court held in Rosenberg v. MetLife (2007) that statements an employer makes on a U5 are absolutely privileged, which bars defamation claims over them under New York law regardless of the employer's motive.
For termination information, FINRA says it will expunge the information from CRD without a court order if the arbitration panel bases expungement on the defamatory nature of the information and states so explicitly in the award. If the panel relies on another ground, such as the U5 being inaccurate or misleading, FINRA requires a court order confirming the award. FINRA's guidance also says employment-related expungement requests that do not involve customer dispute information are not subject to Rules 2080 or 13805.
Customer complaints are handled differently. FINRA Rule 2080 says FINRA will expunge customer dispute information only by court order, with FINRA named as a party unless it waives that requirement, and arbitrators may recommend expungement only on grounds such as the claim being factually impossible or clearly erroneous, false, or not involving the registered person. FINRA's amended expungement rules, including Rule 13805 for requests a broker files against a firm (known as straight-in requests), took effect Oct. 16, 2023. Under Rule 13805, a straight-in request must be filed within two years after the related customer arbitration or litigation closes, or within three years after the complaint was first reported to CRD if there was no arbitration or litigation, and Rule 13806 assigns these requests to three randomly selected public arbitrators eligible for the chairperson roster.
The no-court-order path for defamation may change. In Regulatory Notice 26-06, a 2026 request for comment on modernizing its arbitration rules, FINRA asked whether to keep its policy of expunging defamatory information without a court order or apply a stricter standard, and noted feedback that arbitrators should find a statement was made in bad faith or with malice before awarding defamation relief. As of October 2026, that notice is a request for comment, not a rule change. This guide is general information, not legal advice.
How long does an advisor have to re-register without retaking exams?
FINRA generally requires individuals to requalify by examination if they have not re-registered within two years after their registration was terminated, according to FINRA Regulatory Notice 21-41. The U5 date starts that clock.
FINRA Rule 1240(c) created the Maintaining Qualifications Program, which lets eligible individuals keep their qualifications for up to five years after termination by completing annual continuing education. Individuals whose registration ended on or after March 15, 2022 have up to two years after termination to elect to participate, according to FINRA. The two-year window still applies to those who do not join the program.