IARD Entitlement Forms
Contents
1. or fingerprint cards submission FINRA RAD must initiate process Individual View Individual Information Provides the capability to view information about individuals that have been previously employed or currently employed by your Firm or your Firm s Simultaneous Filing Group ol View CHRI Information BD Only Provides the capability to view an individual s Criminal History Report Information CHRI F Non Filing Information Provides the capability to view the Individual s Non Filing information ice Provides the capability to transition an existing Investment Adviser Representative s State IA Registrations pee Provides the capability to view Individual Notices Registrations Disclosure Fingerprint Exams CE amp Termination Fingerprint Status Received from Provides the capability to view fingerprint statuses received from the FBI FBI Queue Provides the capability to view amp print Criminal History Report Information CHRI received from the FBI View Individual SSN View Individual SSN Provides the capability to view Social Security numbers Form Filing Form U4 Provides the capability to enter Initial Amendment Concurrence Page 2 for BD Schedule A or B Relicense and Dual Registration form filings Form U5 Provides the capability to enter Partial Full and Amendment U5 form filings pee eee Provides the capability to enter BD Amendments and Partial and Full BDW form filings i PeR Provide2. activities they should perform to access the FINRA Entitlement Program and the IARD System The attachment also includes important reminders regarding password security You may distribute this attachment to your users as a reference aid Entitlement Firm Download Report This attachment provides the benefits and instructions for using the Firm Download Report which enables the Account Administrator to review their users and what access they have VII FINRA Entitlement Program Support This attachment provides a reference of support information available for the FINRA Entitlement Program and the IARD System located at the LARD Web Site http www iard com Vi Joint Firms that already have Web CRD access as a broker dealer will use their existing Web CRD entitlement User ID and Password on IARD Joint Firms will not receive a new User ID or Password In addition Joint Firms will use their existing financial account for all Web CRD and IARD transactions Your Firm s IARD Financial Account When you receive your User ID and Password you will be able to access IARD and begin completing the Form ADV on line However you will not be able to submit an electronic filing until funds are deposited into your financial account either by Web E Pay wire transfer or check Your Firm s CRD number should always be written on checks deposited into your IARD Financial Account Details on how to submit funds by Web E Pay wire transfer or
3. check and other important Accounting information can be found at http www iard com fees asp Special Note Please DO NOT send payment along with your Entitlement Forms Funds should be deposited after you have received your Firm s CRD number from the Entitlement Group Support for IARD and User Assistance Tools FINRA has established a dedicated telephone number 240 386 4848 for IARD questions related to the Entitlement Forms system navigation and system usage We request that all questions and or problems you may have using the system be directed to this number If the Call Center staff is unable to answer your question they will route your inquiry to a subject matter expert who will promptly return your call Any questions related to policy interpretation or regulatory requirements should be directed to the SEC s IARD hotline 202 551 6999 or to the SEC s e mail box IARDLIVE sec gov Inquiries concerning state issues should be directed to the NASAA IARD Hotline 202 737 0900 Inquiries regarding the status of filings should be directed to the SEC at 202 551 7250 or appropriate state refer to the Regulator s Directory available on www iard com To assist filers FINRA has created a User s Manual This User s Manual is available for your review and reference at www iard com The manual is designed to allow you to view and print all or part of it as necessary Additionally a series of functional Navigatio
4. for an AA use the IA Firm FINRA Entitlement Modification Form for the IARD System available at http www iard com To delete an AA s account for all applications e g IARD Web CRD etc fax on company letterhead the AA s First and Last Name Organization CRD and the request to delete the AA s account from all applications An IA Firm signatory must sign the deletion request letter Are you the Investment Adviser currently registered as a Broker Dealer in the United States Yes LI No L If YES please complete the following Your Broker Dealer Information a Date of Formaton O Date of Formation Date officially registered as Corporation Partnership LLC LLP Sole Date officially registered as Corporation Partnership LLC LLP Sole Proprietorship etc Your Investment Adviser Information Proprietorship etc Organization Type Organization Type e g Corp Partnership LLC LLP Sole Prop etc e g Corp Partnership LLC LLP Sole Prop etc T Place ofFormationiing L O O State or Country State or Country Business Names 1A Firm CRD i avatabie ____d Pull Busnes Legal Name Primary Busines Name IA Firm SEC or State AAEF Ver 2 FINRA 6 08 Principal Office and Place of Business set adress re couneyel_ le reephone Number a E TT Contact Person NmeL Z O Last First Middle comaet Tite ooo o
5. non public controlled access applications hereinafter FINRA Entitlement Applications requires access to such applications Please note applications covered by this Agreement are listed at http www finra org entitlement FINRA must have a fully executed FINRA Entitlement Agreement FEA on file for your organization prior to processing an FINRA Entitlement Modification Form In addition to completing the FINRA Entitlement Agreement you must complete the appropriate FINRA Account Administrator Entitlement Form AAEF to designate your organization s Account Administrator s Primary and or Alternate to the specific FINRA Entitlement Application your firm is requesting The AAEF can be found at http www finra org entitlement Organization CRDAGtavalable ___d Organization Name ooo I IIU City Sate amp Zip Code FINRA Entitlement Agreement Acknowledgment of Responsibility Organization Name Hereinafter referred to as You or Your and includes your authorized agent or designee does hereby acknowledge and agree that any and all Account Administrators referred to herein as Account Administrator or AA which are i appointed by You in any FINRA Account Administrator Entitlement Form AAEFP ii appointed by You in any other FINRA or non FINRA designated form that purports to appoint any individual s to act as your agent in fact to access and assign access to FINRA applica
6. pg IA Only Firm Employee Service Provider Rep Address CT iy State amp Zip Coded Email jee Telephone ww sanm ooo CRD Participant Firm IA Only AAFF Ver 2 FINRA 6 08 Entitlement Privileges Instructions As the Account Administrator for this application mark the Entitlement Privileges that your Firm requires you to have to perform your job function s Marked privileges will be set to Use Read Grant Any unmarked privileges will be set to Read Grant which will enable you to perform your role as an Account Administrator Entitlement Privileges for Web CRD For CRD Participant Firm IA Only Organization View Organization Information Provides the capability to_view information about your Organization Non Filing Information Provides the capability to view the Firm s Non Filing information contact ioe ere a information trustee information name change history and mass transfer history J Maintain Contact BD Only Provides the capability to view amp maintain the Firm s Contact information Maintain Firm Notification Provides the capability to view amp maintain the Firm s Notification information Firm Queues Provides the capability to view Firm Notices Current Deficiencies Withdrawal or Termination SFG Retirement Mass Transfers Provides the capability to prepare a Mass Transfer of individuals from one Member Firm to another without requiring U4 filings US filings
7. s full ime ona L INITIAL ALTERNATE AA ADD ALTERNATE AA If you are a new Firm or an IA Only Firm before you submit this AAEF your firm must complete and mail an originally signed FINRA Entitlement Agreement If your Primary AA is being replaced make sure you check the Replace Primary AA box and provide the current Primary AA s full name The FINRA Entitlement Group will delete access to the Web CRD Application for the current Primary AA s account when creating the replacement primary AA for Web CRD You do not need to complete the FINRA Entitlement Modification Form for the Primary AA for whom you are designating a replacement To modify disable or delete the Web CRD Application for an AA use the CRD Participant IA Only Web CRD Entitlement Modification Form for the Web CRD Application available at http www iard com To delete an AA s account for all applications e g LARD Web CRD etc fax on company letterhead the AA s First and Last Name Organization CRD and the request to delete the AA s account from all applications A firm signatory must sign the deletion request letter CRD Patipnt IAOny Famers CRD ParcipantIA Only Fim Name CRD Patipnt IA Only Fim Sweet address ooo City State amp Zip Code Laaa Account Administrator If this individual is already an entitled AA User to a FINRA Entitlement Application check here Name First Middle Last Suffix Individual CRD if applicable
8. RD Account Administration Navigation Guide available on the IARD Web Site 3 CRD Participant A Only Account Administrator Entitlement Form CRD Participant A Only AAEF This form must be completed by each person designated as either the Primary AA or Alternate AA The CRD Participant A Only AAEF is used to designate what Web CRD account privileges the AA will have One 1 CRD Participant A Only AAEF form is enclosed in this packet A separate CRD Participant IA Only AAEF must be completed by each Primary AA and the Alternate AA For more information on the role and responsibilities of the AA s refer to the Account Administrator Navigation Guide available on the FINRA Web Site The IARD AA s must complete the CRD Participant A Only AAFF in order to register Investment Adviser Representatives RAs The CRD Participant A Only AAFF is used to designate what CRD account privileges the AA should have You must send the completed FINRA Entitlement Agreement with an original signature and the completed IARD and CRD Participant A Only AAEFs to the FINRA Entitlement Group at the designated address on the forms If you are a Joint BD IA firm and already have access to Web CRD Focus you still must complete and return the FINRA Entitlement Agreement and the IARD AAFF as explained above to gain access to IARD IARD Confirmation Packet and Account ID Information Once FINRA receives and processes your completed FINRA Entitlement A
9. Welcome Investment Advisers Planning To Register with the SEC In 1996 Congress authorized the SEC to establish a one stop electronic filing system for investment advisers and directed the SEC to provide investors with ready access to information about investment advisers The switch from a paper filing system to an electronic filing system formally began in January 2001 through the Investment Adviser Registration Depository IARD As of January 1 2001 the SEC no longer accepts paper filings of Form ADV from investment advisers that want to register with the SEC Instead an investment adviser seeking to become SEC registered must file Form ADV electronically through IARD Before the adviser can make an electronic filing using IARD it must establish an IARD User Account The IARD Entitlement Forms and related information needed to establish an IARD User Account are provided here Print a copy of this Entitlement Packet Fill out the three required forms FINRA Entitlement Agreement IA Firm AAEF and the CRD Participant AAEF sign them and send them to FINRA at the address indicated on the forms Upon receipt of your forms FINRA will create User Accounts for the IARD Account Administrators AAs designated by your firm FINRA will contact your firm s AAs with the Firm s CRD number and User IDs and initial Passwords for accessing IARD In addition FINRA will e mail each AA a link to the Entitlement IARD Confirmation Packet Please note that d
10. ct to and on the applications supported by the FINRA Entitlement Program and that FINRA can and should rely on the actions of Your AA s and Your Subscribers as if they were Your own Further in addition to the indemnification provisions in the FINRA Entitlement Program Agreement and Terms of Use You agree to defend indemnify and hold FINRA harmless from the actions or inactions of You Your AA s and Your Subscribers and from any breaches of the FINRA Entitlement Program Agreement and Terms of Use by You Your AA s or Your Subscribers or for negligent or tortious conduct by You Your AA s or Your Subscribers with respect to the entitlements granted as well as any third party claims based thereon The terms You and Your in this form refer to the organization on whose behalf this form is submitted Subscriber as used herein is as defined in the FINRA Entitlement Program Agreement and Terms of Use By signing below the signatory hereby certifies that s he is authorized to legally bind the Organization on behalf of which s he is executing this Agreement Signature Date Signatory must be an officer of the organization or otherwise have the legal authority to bind the organization Print Name _ Irie of signatory _ Please print clearly Please mail completed form with original signature to FINRA Entitlement Group 9509 Key West Avenue Rockville Maryland 20850 For Questions Call 301 869 6699 for Bro
11. eficient or incomplete entitlement forms could delay your firm s access to IARD Once IARD access is granted you may fill out the Form ADV on your computer and apply to register with the SEC by electronically submitting your Form ADV for review Assuming that your application meets all SEC requirements the SEC will mail you an order approving your registration typically within 45 days and also will notify you electronically through IARD that your registration is approved Notice Filings required by state regulators also will be submitted electronically through IARD with your SEC filing All future amendments to your Form ADV must be made electronically after you are SEC registered To keep informed about developments related to filing on IARD we suggest you check the SEC s IARD Web Site at www sec gov IARD Questions about IARD entitlement forms should be directed to FINRA at 240 386 4848 Please contact the SEC if you have questions about the status of your registration legal or policy questions The phone numbers and email addresses for inquiries to the SEC can be found at www iard com support_contacts asp To Investment Adviser Firms SEC Registration From FINRA Registration and Disclosure Department Re The IARD Entitlement Process FINRA welcomes you to the Investment Adviser Registration Depository IARD This memorandum contains general information about the IARD System and IARD Account Entitlement Forms for investment advis
12. ent and Terms of Use from time to time in its sole discretion and pursuant to the FINRA Entitlement Program Agreement and Terms of Use You are encouraged periodically to review the current FINRA Entitlement Program Agreement and Terms of Use Each use of any of the applications supported by the FINRA Entitlement Program by You Your AA s or Your Subscribers constitutes Your renewed agreement to the FINRA Entitlement Program Agreement and Terms of Use as modified The FINRA Entitlement Program Agreement and Terms of Use contain provisions that govern use of contributions to and access to the applications covered by the FINRA Entitlement Program by You Your AA s and Your Subscribers including but not limited to restrictions on the transfer of Your right to access the applications supported by the FINRA Entitlement Program restrictions on the use and or copying of the applications supported by the FINRA Entitlement Program permission for FINRA to use material submitted by You Your Subscribers or Your AA s via any applications supported by the FINRA Entitlement Program limitations on warranties and damages permissible amendments to the FINRA Entitlement Program Agreement and Terms of Use or Entitlement Forms treatment of private information waiver of rights to a jury trial and choice of law and jurisdiction provisions You further agree that Your Primary AA s Your Alternate AA s and Your Subscriber s can take actions on Your behalf with respe
13. ents to Form ADV ADV W Partial and Full form filings Submit Forms Provides the capability to submit ADV Initial Application and Amendments to Form ADV ADV W Partial and Full form filings Accounting Accounting Provides the capability to view your Firm s IA Accounting data Reports Rere Provides the capability to access ReportMart to retrieve your Firm s IA Reports sjgnawre tae PT Must be signed by a Designated Firm Signatory or a FINRA Account Administrator print Name o Please print clearly Please FAX completed form to FINRA Entitlement Group at 240 386 4669 or mail to FINRA Entitlement Group 9509 Key West Avenue Rockville Maryland 20850 Questions Call FINRA Gateway Call Center at 240 386 4848 IA Firm SEC or State AAEF Ver 2 FINRA 6 08 Financial Industry Regulatory Authority FINRA Account Administrator Entitlement Form AAEF CRD Participant Firm i IA Only Web CRD Instructions Complete this form for each Account Administrator This form must be signed by a Firm s Account Administrator either Primary or Alternate each of which is referred to herein as AA or designated signatory of the firm Please v the specific request below and complete all pages of the form Any field marked with an asterisk is a required field Fax or mail the signed form always include the signature page L INITIAL PRIMARY AA REPLACE PRIMARY AA Current Primary AA
14. ers seeking SEC registration Your firm is requesting access to IARD Web CRD through the FINRA Entitlement Program Once your firm has completed and submitted your Entitlement Forms FINRA will contact the IARD Account Administrators AAs designated by your firm with their Firm s CRD number User ID and initial Password information Note that a form deficiency may delay establishing your IARD User Account so please pay careful attention when completing the Entitlement Forms FINRA will also follow up by sending each AA an e mail with a link to the ARD Confirmation Packet The LARD Confirmation Packet contains six 6 attachments with detailed information to assist AAs INCLUDED IN THIS PACKET ARE THREE 3 FORMS THAT MUST BE COMPLETED AND RETURNED TO FINRA IN ORDER TO ENTITLE YOUR FIRM s ACCOUNT ADMINISTRATOR s TO USE THE IARD and Web CRD SYSTEMS Background Information IARD is a Web based system for registration of investment advisers The United States Securities and Exchange Commission SEC or Commission and the North American Securities Administrators Association NASAA created IARD FINRA is the developer and operator of the system IARD allows SEC registered advisers to file Form ADV and ADV amendments with the Commission and satisfy their Notice Filing obligations with the states at the same time IARD provides regulators with the ability to monitor and process investment adviser information via a single centralized syste
15. greement and IARD and CRD Participant A Only AAEFs FINRA will create User Accounts for the IARD Account Administrators AAs designated by your firm FINRA will contact your firm s AAs with the Firm s CRD number User ID and initial Password for accessing IARD In addition FINRA will e mail each AA with a link to the IARD Confirmation Packet The IARD Confirmation Packet provides AAs with information on their role responsibilities security information and links to other helpful entitlement information The IARD Confirmation Packet contains seven 7 attachments with detailed information to assist you the AA and your organization as a FINRA Entitlement Program participant Recommended Hardware Software Configuration This attachment lists the minimum hardware and software requirements necessary to access and operate the IARD System Il Account Management Tool General Overview This attachment provides information on features of the FINRA Login screens for the AAs and Users Ill IARD Account Administrator Roles amp Responsibilities This attachment provides the roles and responsibilities of an Account Administrator using the Account Management Tool and provides Entitlement Tips IV Password Change Instructions This attachment provides the steps for changing your password and accessing the FINRA Entitlement Program and the IARD System V Password Change Instructions for IARD Users This attachment provides the users with the
16. il please mail to FINRA Entitlement Group P O Box 9495 Gaithersburg MD 20898 9495 To send completed forms via overnight service please mail to FINRA Entitlement Group 9509 Key West Avenue Rockville MD 20850 Completing Account Entitlement Forms the FINRA Entitlement Agreement the IA Firm AAEF and the CRD Participant A Only AAEF The IARD System is a secure system These forms are used to identify all Account Administrators AAs authorized by your firm to access ARD The AA s is the person s responsible for creating and maintaining your firm s IARD User Accounts The AA also establishes user accounts to enable Firm users to access the system 1 FINRA Entitlement Agreement This form must be signed by an officer of the organization or by an individual within the organization who has the legal authority to bind the organization All fields must be completed FINRA requires the FINRA Entitlement Agreement to be signed with an original signature This form cannot be faxed 2 IARD Account Administrator Entitlement Form IA Firm AAEF This form must be completed by each person designated as either the Primary AA or Alternate AA The IA Firm AAFF is used to designate what IARD account privileges the AA should have One 1 IA Firm AAFF form is enclosed in this packet A separate A Firm AAEF must be completed by each Primary AA and Alternate AA For more information on the role and responsibilities of the AA s refer to the IA
17. inations are submitted on Form U4 and Form US filings via Web CRD Role of FINRA In its role as the operator of the IARD System FINRA is responsible for designing and operating the system according to the requirements specified by the SEC and NASAA FINRA also oversees entitlement to the ARD System system maintenance and availability FINRA staff are available to answer your questions regarding the Entitlement Forms system navigation and system usage FINRA has no regulatory authority over investment advisers The review of adviser filings is done entirely by the SEC and or states with whom you file FINRA staff cannot advise you on the legal status of filings once they are submitted to the IARD System IARD Entitlement Included in this packet are the three forms you must complete and return to FINRA in order to establish an IARD User Account for your firm These forms must be returned with original signatures to FINRA Entitlement Setting Up Your IARD User Account The first step in setting up your Firm s IARD User Account is to complete the three 3 FINRA forms in this packet 1 The FINRA Entitlement Agreement FEA 2 the IA Firm Account Administrator Entitlement Form IA Firm AAEF and 3 the CRD Participant A Only Account Administrator Entitlement Form CRD Participant IA Only AAEF Send the completed forms to the FINRA Entitlement Group either by regular mail or by overnight service To send completed forms via regular ma
18. ker Dealer Firms 240 386 4848 for IA Only Firms FINRA Entitlement Agreement Ver 1 FINRA 7 07 Financial Industry Regulatory Authority FINRA Account Administrator Entitlement Form AAEF IA FIRM SEC amp State lsecia rmm _ sraTe1A FIRM IARD Instructions Complete this form for each Account Administrator This form must be signed by an Investment Adviser IA Firm s Account Administrator either Primary or Alternate each of which is referred to herein as AA or designated signatory of the firm Please v the specific request below and complete all pages of the form Any field marked with an asterisk is a required field Fax or mail the signed form always include the signature page INITIAL PRIMARY AA REPLACE PRIMARY AA Current Primary AA s full name Loy INITIAL ALTERNATE AA ADD ALTERNATE AA If you are a new Firm or an IA Only Firm before you submit this AAEF your firm must complete and mail an originally signed FINRA Entitlement Agreement If your Primary AA is being replaced make sure you check the Replace Primary AA box and provide the current Primary AA s full name The FINRA Entitlement Group will delete access to the IARD Application for the current Primary AA s account when creating the replacement Primary AA You do not need to complete the FINRA Entitlement Modification Form for the Primary AA for whom you are designating a replacement To modify disable or delete the IARD System
19. m The CRD System was developed jointly by the National Association of Securities Dealers NASD and the North American Securities Administrators Association NASAA The CRD system was first launched in 1981 to centralize the registration process for the securities industry 1 e BD amp agent The CRD system enabled one stop filing i e the ability to submit one application seeking registration in all jurisdictions and self regulatory organizations The CRD system streamlined the registration process by maintaining the qualification employment disclosure histories fingerprint process registration fees and renewal fees Over the past two 2 decades it has been expanded and modified extensively to meet the evolving needs of the FINRA s constituencies All states that register investment advisers and their representatives participate in Web CRD and accept filings submitted via the Web CRD System When you file through IARD you can complete your electronic Form ADV over a period of time and save the filing as a draft or pending filing It is important to know that no one other than people entitled by your firm as users can view pending filing information Only after you submit the filing to IARD does it become available for viewing by regulators Investment adviser representative registration was implemented through the Web CRD System on March 18 2002 Investment Adviser Representative RA registration requests and term
20. n Guides have been developed to be used as quick reference tools for users on how to use the system They are not meant to replace the Users Manual Rather the Guides are a support tool to keep handy by your PC These Navigation Guides are available on the IARD Web Site at www iard com We anticipate your experience with electronic filing on the IARD System will be a smooth one Please remember to use the support tools that have been put in place to assist you when you have questions FINRA looks forward to working with you as you use IARD Please refer to the IARD Web Site at www iard com for additional information and guidance on setting up your firm s IARD User Accounts or contact the IARD Hotline at 240 386 4848 For additional information on Web CRD and Investment Adviser Representative RA registration and termination requests on the Forms U4 and US please refer to the FINRA Central Registration Depository CRD Web Site Financial Industry Regulatory Authority FINRA Entitlement Agreement Instructions This form must be signed by an officer of the organization or by an individual within the organization who has the legal authority to bind the organization All fields must be completed Mail the signed FINRA Entitlement Agreement to the address shown on the signature page This form cannot be submitted via facsimile The FINRA Entitlement Agreement is required when an organization that is not currently entitled to certain FINRA
21. s the capability to enter amp submit BR Initial Amendment and Closing Withdrawal form filings LI Form Non Registered FP BD Only Provides the capability to enter Non Registered individuals fingerprint cards Accounting L Accounting Provides the capability to view your Firm s Accounting data Reports LJ Reports Provides the capability to access ReportMart to retrieve your Firm s Reports signawre e Must be signed by a Designated Firm Signatory or a FINRA Account Administrator Print Name L____ I T Please print clearly Please FAX completed form to FINRA Entitlement Group at 240 386 4669 or mail to FINRA Entitlement Group 9509 Key West Avenue Rockville Maryland 20850 Questions Call FINRA Gateway Call Center at 240 386 4848 CRD Participant Firm IA Only AAFF Ver 2 FINRA 6 08
22. sses eo belb ronm laL Account Administrator If this individual is already an entitled AA User to a FINRA Entitlement Application check here O C First Middle Last Suffix Individual CRD if applicable Ld LJ JA Firm Employee O Service Provider Rep Address DT City Sate amp Zip Code Email Address ae Telephone Number Fax Naber L_ IA Firm SEC or State AAEF Ver 1 FINRA 7 07 Entitlement Privileges Instructions As the Account Administrator for this application mark the Entitlement Privileges that your Firm requires you to have to perform your job function s Marked privileges will be set to Use Read Grant Any unmarked privileges will be set to Read Grant which will enable you to perform your role as an Account Administrator Entitlement Privileges for IARD For IA Firms IA Organization IA View Organization Provides the capability to view information about your IA Firm Information IA Non Filing Information Provides the capability to view the Firm s IA Non Filing Information Transitions Provides the capability to transition state registrations and Notice Filings onto the system Firm Queues sd Provides the capability to view Firm IA Notices View Individual SSN View Individual SSN_______ Provides the capability to view Social Security numbers _ Form Filing Form ADV and ADV W Provides the capability to enter ADV Initial Application and Amendm
23. tions iii any other individual given access to FINRA applications by You regardless of whether such individual was formally appointed as Your AA or iv as otherwise authorized by You have the authority to act on Your behalf with respect to the entitlements granted and that You take responsibility for such actions You also acknowledge and agree that any and all AAs You appoint have the authority to obtain distribute revoke and monitor entitlements granted by FINRA for the specific applications materials and services established by FINRA and to act on Your behalf with respect to the entitlements granted and that You take responsibility for such actions An AA may authorize Subscribers and may submit information for the application s for which s he has been properly authorized to act as an AA All applications materials and services for which entitlements are hereby granted are governed by the FINRA Entitlement Program Agreement and Terms of Use You may obtain copies of the most current version of the FINRA Entitlement Program Agreement and Terms of Use by going to the FINRA Entitlement web page at http www finra org entitlement_or by contacting FINRA You hereby acknowledge and agree that You have read and agree to the FINRA Entitlement Program Agreement and Terms of Use without exception or alteration which are contained in the FINRA Entitlement Program Agreement and Terms of Use FINRA may revise the FINRA Entitlement Program Agreem
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