SEC Issues No-Action Relief from Rule 17a-4 for Electronically Signed U4 Filings Maintained in the CRD System.

On September 5, 2025, the SEC granted no-action relief that allows FINRA members to rely on the Central Registration Depository system (“CRD”) to satisfy their record retention requirements under Rule 17a-4 (“Rule 17a-4”) under the Exchange Act with respect to Form U4 (Uniform Application for Securities Industry Registration or Transfer) filings that are electronically signed by individuals using FINRA’s electronic signature functionality (“FINRA E-Signature functionality”) and maintained on CRD (the “2025 Letter”)

This 2025 No-Action Letter expands existing SEC no-action relief from the “2008 Letter”) by allowing FINRA members to rely on CRD to maintain a broader array of registration-related records required to be retained under Rule 17a-4.3 It thereby relieves members of the administrative burden and cost of storing Forms U4 already maintained on CRD.

Please refer to the respective No-Action Letters for detailed information.

2025 No-Action Letter:

https://www.sec.gov/files/tm/no-action/finra-u4-recordkeeping-nal-outgoing-final-090525.pdf

2008 No-Action Letter:

https://www.sec.gov/divisions/marketreg/mr-noaction/2008/finra021908.pdf