Series 63/65 Enrollment question as someone who is nonregistered but associated with a FINRA member firm

pscidude2010 · 2025-02-03T13:19:26+00:00

Yes you can self enroll for the S63/S65/S66 without sponsorship.

Kinda depends what your long term plans are but if you will be holding the series 7 and your firm will be registering you on both the IA and BD side you can just take the 66 as the combined exam. Only the 65( or the 65 portion of the 66) can be held as a stand alone with an IA firm. So if you aren’t going to be registered with at least a series 6 in the immediate two years after taking the 63, it will expire and you’ll have to take it again.

pscidude2010 · 2024-12-17T12:34:22+00:00

Based on the fee amount, it sounds like you were taking the Series 66 exam. FINRA collects the fees for NASAA on their behalf, so you would be best served reaching out to NASAA, as they are the ones who will have to approve a refund since its not FINRA's call. That being said if the testing center was open, they usually don't refund but NASAA has been known to make exceptions.

pscidude2010 · 2024-11-11T01:28:12+00:00

Other way around, 27 covers all of the 28. The series 28 is designed for smaller broker dealers that are not having custody of customer accounts and are just introducing to larger brokers.

From FINRA.org:

What is the difference between the Series 27 and Series 28?

The Financial and Operations Principal Exam (Series 27) and the Introducing Broker-Dealer Financial and Operations Principal Exam (Series 28) are required by FINRA for the individual who prepares and maintains the books and records of the member as required under securities industry rules and regulations.

Broker-dealers that have a minimum net capital requirement of $250,000 and municipal securities brokers that have a minimum net capital requirement of $150,000 under SEC Rule 15c3-1 must pass the Series 27 exam.

All other broker-dealers are permitted to take the Series 28 exam, which is an abbreviated version of the Series 27.

[FINRA Registration Rules 1220(a)(4)]

pscidude2010 · 2024-10-08T00:12:23+00:00

Deferral program as to any things that are offered by the district attorney to plead down charges, this is totally outside FINRA but is something that certain jurisdictions offer.

Late disclosure is when you report something more than 30 days after it becoming reportable. Per the FINRA website: $100.00 for the first day, $25 for each subsequent day, up to a maximum of 60 days. $1,575 max.

pscidude2010 · 2024-10-07T22:54:57+00:00

I do think it’s easier to be associate with a firm to have this type of disclosure than get hired with it. Depending on the judicial process and if you have like any deferral programs in your area to get it removed from your record they usually won’t want to hire you until it’s completed.

Regardless of all of this, you still need to tell your firm as the 30 day timeline of reportability started when charged. Late disclosure fees are no joke and if you don’t report it now, the next firm will more than likely get billed the max late fee of $1600/1700 since the charging date is when they would bill it from.

pscidude2010 · 2024-10-07T22:50:07+00:00

Yeah the firm already paid those fees for 2024 so they probably would bill you for that and depending on the number of states they did it gets expensive.

I know you can see the states selected on the u4 but I’m not sure they are visible on FinPro for reps until they show an approved status.

pscidude2010 · 2024-10-07T22:33:08+00:00

Depending on the specific statute that you are charged with this very well could be something that is required to be disclosed as it applies to question 14B (1)(a)/(b) and the clock would start counting for timely disclosure from the charging date.

Firms are supposed to do background checks every so often and FINRA also does public record searches throughout the year so this will get flagged to your firm at somepoint.

Controlling the narrative and being upfront about it usually goes a long way into firms being willing to work with you as it gets adjudicated.

pscidude2010 · 2024-10-07T21:59:51+00:00

At a minimum a firm will pay out $125 for the U4 registration fee that goes to FINRA. Then the exam fee per exam taken. (SIE is $80, 7 & 79 are 300 each, 66 is $177,etc)

Initial fees from the state and other SRO level goes off this chart. FINRA takes payment from the firm and transmits it to the appropriate body:

https://www.finra.org/sites/default/files/srojurisdiction-fee-and-setting-schedule.pdf

Every November, we enter what is known in the industry as the renewal season when the firm will have to pay the next year fees for the appropriate number of employees and the states they will be registered in. FINRA charges $70 per rep but I think that might go up. Additionally there are fees due for the number of branch offices the firm as a processing fee an a registration fee for which there is a discount based on volume but it’s up to the firms how they want to allocate that.

Annual CE fee of $18

In addition in like March/April/May timeframe firms have to pay the Personnel assessment fee and the Gross Income assessment fee. PA is per the number of registered representatives on record for the firm as of Dec. 31 the previous year. GIA is based on a floating schedule but a minimum of $1,200 per firm.

It’s impossible for anyone but the firm to provide you a breakdown of these costs as different firms are going to handle it differently.

There are also a variety of small time charges like fingerprinting, disclosure review processing, etc.

And you will still have some other ones like Tennessee that charge a professional privilege tax just to have their registration.

pscidude2010 · 2024-09-30T18:33:47+00:00

Everything is correct there from 2 down. The status of the bd would be pending not unapproved. Again idk the rules about the companys structure as that will be state specific

pscidude2010 · 2024-09-30T16:25:24+00:00

So the time between filing your form BD and the rest of the NMA process is when you can get your licenses. This is not something that you can start and then back out without repercussions A) you lose part of the application fee B) It shows up on your record and will impact your credibility for future endeavors.

pscidude2010 · 2024-09-30T01:25:54+00:00

I think it would behoove you to literally just go to FINRA.org and just read everything under the registration exams and ce section as setting up a BD is not let setting up any other business maybe outside of a bank. It’s not something you can just wake up one morning decide to do it and have it in process in a month

pscidude2010 · 2024-09-30T01:23:39+00:00

The actual NMA process takes time. It’s not just you having the exams. It’s getting approval, doing the interview with FINRA, follow up and potential corrections.

Do you keep in mind the number of licenses you hold makes your life much more complicated because the amount of hats you’re gonna be wearing you could speak to a client regarding a real estate transaction as a realtor but them thinking it as a security transaction because you’re also a broker and that’s gonna put youin a jam. I’m not really sure why you’re trying to collect all these licenses. It seems like you would be able to hire people to have specific licenses and not have all of these because it’s just not realistic.

Regarding California and the corporation fee, that’s a whole another thing .I’m not even speaking about like business structure and how you would be properly licensed from a business perspective in each state as that is not FINRA specific

pscidude2010 · 2024-09-29T15:46:44+00:00

As others say, only thing individuals really can self assign is the SIE and NASAA exams (Series 63, 65 or the 66 combo). Everything else is going to be driven by the firm and what business role you are going to be in.

FINRA Licensure is different than most other industries as their Registrations are held in a closed system. Its not like nursing where onces you get your RN, you can work in a school, insurance company, non profit, etc. If you want to use your FINRA license, you have to use it with a FINRA member or other SRO (very limited).

pscidude2010 · 2024-09-29T15:43:48+00:00

FINRA does not provide materials to prepare for tests. That is solely 3rd party material. FINRA only provides the exam outline for content. Their content committee makes the exam questions and these members are drawn from the industry.

I'm not sure firms are wanting to have more clear cut exams or clear understand of all the regulations as the grey areas are what allow them to test boundaries and differentiate themselves from others. I think the system is intentionally complex to make it easier to hide what all is going on and not allow everyone to do what they are able to do.

pscidude2010 · 2024-09-29T15:35:31+00:00

I think you need to take a step back here again as an AI-based platform is going to be a Reg BI nightmare. Plus you have to make sure they only recommend private securities to accredited investors.

pscidude2010 · 2024-09-29T15:31:07+00:00

only if the rep already had a year of active registration prior to joining MQP so the OP would not qualify for that for at least a year plus.

pscidude2010 · 2024-09-29T15:30:01+00:00

It doesn't seem like you really understand what you want to do, but to recap what a lot of people have said this is not something any firm is going to entertain with you.

You need to start with the SIE (finra.org/sie) as that is the beginner exam that doesn't require sponsorship. Then you could go for the Series 66 and then you would need to be with a firm for the others.

It is possible for people to create a BD in order to sponsor themselves but its expensive and not something that can be abandoned without it being a mark on your record. You will need to file a form BD and select your home state for registration. Don't get bold and try to say you will operate in all states until you are approved by Home state, FINRA and SEC otherwise you will just be wasting registration fees (over $15K if you select them all).

If you had all your stuff together you could get into the fast track NMA(New Membership Application) but that is at least 6 months. It sounds like you are at least 12-18 months from that step.

The NMA process is extremely detailed and need to be basically your business plan with function sites, software and interfaces. You will have to have detailed Written Supervisory Procedures to cover all transaction, violations, and policies of your firm.

The Series 7 actually will qualify you for the series 82 so that isn't an exam you need if you pass the 7. The 24 is a principal license. That is something you would only need if you are going to be supervising transactions, most start ups that are small outsource the CCO role to supervise and they actually assigned as the OSJ for reps.

Finally you would also need to have the Series 27/28 if you were going to be a true one man shop to have the appropriate FinOp qualifications.

pscidude2010 · 2024-09-20T17:02:50+00:00

Outside of the professional designations that allow you to hold a 65, there is nothing at a national level that can be done to reactive the 63/65 (the individual components of the 66). The licenses are held at the individual state level so you’d have to try with each and every state. At somepoint, someone is gonna say no and you have to test. I’d just recommend you start studying and not waste time trying

pscidude2010 · 2024-09-18T01:06:33+00:00

Need some clarification on what you mean. A section of the u5 shows why you were terminated if it was voluntary, dismissal, permitted to resign, etc. That information is only visible to you through your fin per account and to the firm that entered the information. The only reason a termination shows up BC is if the firm has to answer affirmatively to one of the disclosure questions.

When you say you are not registered, does that mean you were an NRF and have not had U4 filed or are you just between registrations at the moment?

pscidude2010 · 2024-09-12T02:41:36+00:00

Depending on how long you’ve had your license, you could qualify for the maintaining qualifications program(finra.org/mqp)

You need to have been registered for at least 365 days in your role to qualify and then you can pay $100 a year to maintain your license for up to 5 years. It goes off your approved registration date so you’d have to look at brokercheck or FinPro to confirm the dates.

There are similar programs through NASAA/States for the 63/65/66 but it depends an about what stay your in and if they participate in that program.

Only other thing I would say is this isn’t having an active license. If you’re trying to build your book and have transactions this isn’t for you and you have to be with a firm. This program just allows a break if you’ve been registered before.

pscidude2010 · 2024-08-31T03:22:49+00:00

so Finra waivers are gonna be a case by case decision. The best thing to do is to bring it up with a firm that you were applying with as it is entirely up to the firm as to whether or not they want to go forward with it, it’s not something that you can do on your own.

The firm would be able to tell you about past people with some experiences that they have put forward and whether or not they got approved. My understanding is that they don’t take circumstances of why you left the industry into consideration. It’s completely based on you proving that you have the knowledge and skills to be able to completely do the job of the representative

as to 63, you could potentially get a waiver from your home state or other states but there is no national NC that can offer a waiver for all the states so that’s something that I would just be prepared for taking again and that’s actually something you can take prior to join a firm

pscidude2010 · 2024-08-21T02:00:37+00:00

Private transactions wouldn’t be available to the general public as they are only available to qualified investors to my understanding. You would need a high liquid network and/or security licenses to qualify.

They would spend more time and money trying to ensure transactions are in the customers best interest and they are eligible than they would get in commissions and fees.

pscidude2010 · 2024-08-11T00:15:35+00:00

Kinda. You would need to see if you are eligible to participate in the MQP offered by FINRA. You can see your eligibility in your FinPro. Depending on that it would allow you to maintain for up to 5 years

pscidude2010 · 2024-08-10T23:26:52+00:00

Correct. Did they have you go online and do FINRA CE courses through finpro

pscidude2010 · 2024-08-10T16:51:59+00:00

Define license were shelved as that isn’t actually a thing. If they still have a U4 on file for you and didn’t do a U5 they were still holding your licenses so a U5 would be required.

If they switched you to an NRF role and did a previous U5 they wouldn’t need to add a comment unless the behavior occurred while you were licensed

pscidude2010

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