Study and Recommendations on Improved 

Investor Access to Registration Information 

About Investment Advisers and Broker-Dealers 

As Required by Section 919B of the 

Dodd-Frank Wall Street Reform 

and 

Consumer Protection Act 

This is a Study by the Staff of the Office of Investor Education and Advocacy 

of the U.S. Securities and Exchange Commission. The Commission has 

expressed no view regarding the analysis, findings, or conclusions contained 

herein. 

_________________________________ 

January 2011 
 

1

I. Introduction

A. The Congressional Mandate 

The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank 

Act” or “Act”) was signed into law on July 21, 2010.1 Section 919B of the Act directs the 

Securities and Exchange Commission (the “Commission” or “SEC”) to complete a study, 

including recommendations, of ways to improve the access of investors to registration 

information about registered and previously registered investment advisers, associated persons of 

investment advisers,2

 brokers and dealers and their associated persons,3 and to identify 

additional information that should be made publicly available. The Act specifies that the study 

include an analysis of the advantages and disadvantages of further centralizing access to 

registration information, and identify data pertinent to investors and the method and format for 

displaying and publishing the data to enhance the information’s accessibility and utility to 

investors. The Act requires the Commission to complete the study within six months after the 

date of enactment of the Act (i.e., by January 21, 2011), and to implement any recommendations 

within eighteen months after completion of the study. 

 

1

 Pub. L. No. 111-203, 124 Stat. 1376 (2010). 

2

 Section 202(a)(17) of the Investment Advisers Act of 1940 [15 U.S.C. 80b-2(a)(17)] defines “person 

associated with an investment adviser” in relevant part as “any partner, officer, or director of such 

investment adviser (or any person performing similar functions), or any person directly or indirectly 

controlling or controlled by such investment adviser, including any employee of such investment 

adviser . . . .” 

3

 Section 3(a)(18) of the Securities Exchange Act of 1934 [15 U.S.C. 78c(a)(18)] defines “person 

associated with a broker or dealer” in relevant part as “any partner, officer, director, or branch manager 

of such broker or dealer (or any person occupying a similar status or performing similar functions), any 

person directly or indirectly controlling, controlled by, or under common control with such broker or 

dealer, or any employee of such broker or dealer . . . .”
 

2

 

B. Organization of the Study 

The Commission’s Office of Investor Education and Advocacy (“OIEA”) prepared the 

study in consultation with the Division of Investment Management, the Division of Trading and 

Markets, the Division of Risk, Strategy, and Financial Innovation, and the Office of the General 

Counsel (collectively, the “Staff”). 4 OIEA also sought input from the Financial Industry 

Regulatory Authority, Inc. (“FINRA”), an industry self-regulatory organization (“SRO”), and the 

North American Securities Administrators Association (“NASAA”).5

 The study does not 

necessarily reflect the views of the Commission or the individual Commissioners. The study 

was approved for release by the Commission.6

The study is organized into eight sections. Following this introductory section, Section II 

provides an executive summary of the study. Section III contains an overview of the registration 

information the Staff believes is important to investors, as well as a brief introduction to the 

primary sources of publicly available registration information. Section IV discusses brokerdealer registration and disclosure, including a history of the Central Registration Depository 

4

 The Staff reviewed, among other things, prior Commission releases, comment letters pertaining to other 

relevant Commission regulatory actions, and empirical data obtained from FINRA and NASAA. The 

Commission has provided the opportunity for the public to comment generally on regulatory initiatives 

to be undertaken in response to the Dodd-Frank Act. See request for public comments on SEC 

regulatory initiatives under the Dodd-Frank Act at 

http://www.sec.gov/spotlight/regreformcomments.shtml. There were no public comments submitted 

regarding the Section 919B study. While the Staff did not speak directly with individual investors in 

connection with this study, the Staff recommends (as described in greater detail in Section VII) investor 

testing or other means of soliciting investor input related to registration information as part of the 

Commission study of the financial literacy of investors required by Section 917 of the Dodd-Frank Act. 

5

 NASAA is a voluntary association whose membership consists of sixty-seven state, provincial, and 

territorial securities administrators in the fifty U.S. states, the District of Columbia, Puerto Rico, the 

U.S. Virgin Islands, Canada, and Mexico. 

6

 The Chairman of the Commission did not participate. 
 

3

 

(“CRD”) and BrokerCheck. 7 Section IV also discusses the registration information available 

through BrokerCheck, as well as the format and usage of BrokerCheck. Section V discusses 

investment adviser registration and disclosure, including a history of the Investment Adviser 

Registration Depository (“IARD”) and Investment Adviser Public Disclosure (“IAPD”), the 

public disclosure arm of IARD. 8

 Section V also discusses the type of registration information 

available through IAPD, as well as IAPD format and usage. Section VI compares the nature of 

information available in BrokerCheck and IAPD. 

Section VII proposes several recommendations. For the near-term, i.e., within the 

eighteen-month implementation period, the Staff makes the following recommendations: (1) 

unify search returns for BrokerCheck and IAPD to help investors more easily obtain the data 

they need to make informed decisions regarding financial services providers; (2) add a search by 

ZIP code or other indicator of location to BrokerCheck and IAPD to increase the utility of the 

existing databases; and (3) enhance BrokerCheck and IAPD by adding educational content to 

make the data currently available more useful to investors. 

The Staff also recommends that, subsequent to the eighteen-month implementation 

period, Commission staff and FINRA continue to analyze, including through investor testing, the 

7

 BrokerCheck is the online application, developed by FINRA, through which the public may obtain 

information regarding current and former FINRA member firms, and current and former associated 

persons of FINRA member firms. The Central Registration Depository (CRD®) is the securities 

industry online registration and licensing database developed by FINRA in consultation with the states. 

Information in CRD is obtained through forms that broker-dealers, registered representatives, and 

regulators complete as part of the securities industry registration and licensing process. The information 

made available through BrokerCheck is derived from CRD. 

8

 The IARD database is comprised of information concerning all SEC-registered investment advisers, as 

well as most advisers that have registered or applied for registration with state regulators since 2001. 

IAPD provides online access to records for SEC and state-registered advisers, and was expanded in 

mid-2010 to include records for registered investment adviser representatives. 
 

4

feasibility and advisability of expanding BrokerCheck to include information currently available 

in CRD, as well as the method and format of publishing that information; and that Commission 

staff continue to evaluate expanding IAPD content and the method and format of publishing that 

content, including through investor testing. Section VIII concludes the study. 

II. Executive Summary

This study responds to Section 919B of the Dodd-Frank Act, which mandates that the 

Commission study ways to improve the access of investors to registration information about 

investment advisers and broker-dealers, including analyzing the advantages and disadvantages of 

further centralizing access to registration information contained in CRD and IARD. 

The Commission and its staff have long maintained that investors should examine 

relevant registration information before choosing a broker-dealer or investment adviser.9

 

Information pertaining to a broker-dealer or investment adviser’s federal or state registration, 

such as information about its associated persons, including licensing and other qualification data, 

disciplinary and employment history, contact information, and customer complaints, can help 

investors make better-educated decisions in selecting a broker-dealer or investment adviser, as 

well as better protect themselves against fraud. 

Currently, a significant amount of registration data is publicly available, primarily 

through BrokerCheck (for broker-dealers and their associated persons who are registered) and 

 

9

 See, e.g., Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 n.5 (Aug. 12, 2010)] 

(adopting amendments to Form ADV) (stating that “the disclosure clients and prospective clients 

receive is critical to their ability to make an informed decision about whether to engage an adviser and, 

having engaged the adviser, to manage the relationship”); Investment Advisers Act Release No. 1897 

(Sept. 12, 2000) [65 FR 57438, 57445 (Sept. 22, 2000)](adopting rules and rule amendments requiring 

electronic filing by investment advisers) (stating that the amendments were “necessary” to, among other 

things, “develop a database of information about advisers that is easily accessible to investors”). 
 

5

 

IAPD (for investment advisers and their associated persons). Additionally, both the Commission 

and state securities regulators require investment advisers to deliver to advisory clients brochures 

and brochure supplements regarding employees, including investment adviser representatives, 

who provide advisory services.10 State securities regulators also act as an important source of 

registration information about broker-dealers, certain investment advisers, and their associated 

persons. This study provides the background and history of both BrokerCheck and IAPD and 

describes the data publicly available on each system. 

While the current process enables investors to obtain registration information about a 

broker-dealer or investment adviser, improvements could be made within the statutorilymandated eighteen-month period that would further promote investors’ interests. In that context, 

the Staff makes a number of recommendations. First, the Staff, pursuant to Section 919B, 

considered the advantages and disadvantages of further centralizing the two systems. The 

primary advantage would be to provide investors access to relevant data through one request, 

regardless of whether they seek data about a broker-dealer or an investment adviser. The Staff 

believes that a unified public disclosure database would be optimal to achieve this goal. 

However, the practical difficulties involved – including Section 919B’s eighteen-month 

10 See Investment Advisers Act Release No. 3129 (Dec. 28, 2010) [76 FR 255, 256 (Jan. 4, 2011)] 

(extending compliance dates for delivery of certain brochure supplements). Generally, all investment 

advisers registered with the Commission as of December 31, 2010, and having a fiscal year ending on 

December 31, 2010 through April 30, 2011, have until July 31, 2011 to begin delivering brochure 

supplements to new and prospective clients, and until September 30, 2011 to deliver brochure 

supplements to existing clients. Id. Brochure supplement delivery deadlines remain unchanged for 

existing registered investment advisers with fiscal years ending after April 30, 2011. Id. Newlyregistered investment advisers filing their applications for registration from January 1, 2011 through 

April 30, 2011 generally have until May 1, 2011 to begin delivering brochure supplements to new and 

prospective clients, and until July 1, 2011 to deliver brochure supplements to existing clients. Id. 

Brochure supplement delivery deadlines for investment advisers filing registration applications with 

the Commission after April 30, 2011 remain unchanged. Id. 
 

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timeframe for implementation – militate toward a near-term recommendation that would involve 

less structural change. As a result, the study recommends unifying search returns for 

BrokerCheck and IAPD while continuing to maintain the separate databases. This would allow 

investors to find registration information on both broker-dealers and investment advisers, 

regardless of whether investors are using BrokerCheck or IAPD. 

Second, the study includes two additional recommendations pertaining to increasing the 

usefulness of the systems to investors. The Staff recommends that BrokerCheck and IAPD 

search functions be expanded to permit searches for broker-dealers, investment advisers, 

registered representatives, and investment adviser representatives, based on ZIP code or other 

indicator of location. This feature would offer a valuable tool for investors who are beginning a 

search for a broker-dealer, investment adviser, or registered person, but who have limited online 

access to registration data organized by location. The Staff further recommends that 

BrokerCheck and IAPD be enhanced by adding educational content, such as links and 

definitional material, perhaps, embedded in alternate text tags (e.g., “bubbles,” “pop-ups,” or 

other kinds of “hover” text) that would appear automatically whenever a user’s electronic cursor 

hovers over certain text or items on the BrokerCheck and IAPD Web pages. These functions 

would provide definitions or other explanatory content to help a user better understand the 

significance of a particular technical term or reference. Both Forms BD and ADV contain a 

glossary of terms that could be used to populate the hover text. 

The Staff also recommends that, subsequent to the eighteen-month implementation 

period, Commission staff and FINRA continue to analyze, including through investor testing, the 

feasibility and advisability of expanding BrokerCheck to include information currently available 
 

7

in CRD, as well as the method and format of publishing that information; and that Commission 

staff continue to evaluate expanding IAPD content and the method and format of publishing that 

content, including through investor testing. Potential modifications could include adding 

summary data for advisory firms on IAPD, hyperlinks between CRD numbers and SEC file 

numbers containing information related to a particular CRD number, and additional links to 

content available elsewhere on BrokerCheck or IAPD. 

III. Background: Registration Information Pertinent to Investors and an Overview of 

Sources of Publicly-Available Data

A. Registration Information Pertinent to Investors 

Because selecting a broker-dealer or investment adviser is one of the most important 

decisions that investors face, information to help them make this choice should be easy to find, 

easy to use, and easy to understand. The Commission recognizes that “[i]nvestors are entrusting 

registered representatives with their savings and should have sufficient pertinent information 

available to enable them to select a registered representative with whose background they are 

comfortable.”11 Accordingly, the Commission has recommended that the investing public use 

all available sources of information to conduct thorough searches of any associated person’s 

activities.12

OIEA encourages investors to evaluate thoroughly the background of any broker-dealer 

or investment adviser that they use or plan to engage. Significant aspects of OIEA’s investor 

 

11 Exchange Act Release No. 59916 (May 13, 2009) [74 FR 23750, 23754 (May 20, 2009)] (approving 

rule change relating to changes to Forms U4, U5, and FINRA Rule 8312 (SR-FINRA-2009-008)). 

12 See, e.g., Exchange Act Release No. 61002 (Nov. 13, 2009) [74 FR 61193 (Nov. 23, 2009)] (approving 

rule change relating to BrokerCheck disclosure (SR-FINRA-2009-050)); Exchange Act Release No. 

55127(January 18, 2007) [72 FR 03455 (January 25, 2007)] (approving SR-NASD-2003-168). 
 

8

 

education and outreach program are based on the premise that investors can better avoid fraud 

and potential investment losses if they gather pertinent data before engaging a broker-dealer or 

investment adviser.13 The information that the Commission believes is important for investors to 

consider in their decision-making is described in a series of OIEA publications, including Invest 

Wisely: Advice from Your Securities Regulators,

14 Ask Questions, 15 and Protect Your Money: 

Check Out Brokers and Investment Advisers.

16 These educational and outreach materials, that 

can be requested directly from financial firms or from federal or state regulators, describe 

various types of information that investors should consider, including: 

• the registration status of the firm and its representatives with state or federal 

regulators; 

• basic information about the firm and its representatives, including the primary place 

of business, formal business address, and contact information; 

• a listing and description of the licenses held by the financial services provider, such 

as a series 7, 65, or 66, and the dates of passage of those examinations by registered 

representatives; 

• descriptions of the credentials of investment advisers and financial planners; 

13 See http://www.sec.gov/investor/pubs/askquestions.htm. A recent national study of the financial 

capability of American adults sponsored by the FINRA Investor Education Foundation found that only 

15% of respondents who have used a financial services provider in the last five years claimed to have 

checked the background, registration, or license of a financial services provider. See Financial 

Capability in the United States, at 46 (FINRA Investor Education Foundation, Dec. 1, 2009). As this 

statistic indicates, continued education is warranted to help investors better understand the importance 

of conducting a thorough review of available information on financial services providers by using 

BrokerCheck and/or IAPD.

14 See http://www.sec.gov/investor/pubs/inws.htm

15 See http://www.sec.gov/investor/pubs/askquestions.htm

16 See http://www.sec.gov/investor/brokers.htm
 

9

 

• the educational background of registered persons; 

• recent employment history of registered persons, particularly details about tenure 

with financial firms with a focus on the frequency of job changes or changes in the 

names of firms they represent; 

• the disciplinary record of the firm and the registered person; 

• a description of current and historic arbitrations, complaints, or litigation by clients 

against a firm or registered person; 

• Form ADV for registered investment advisers; 

• a description of the scope and type of investment services offered by the brokerdealer or investment adviser; 

• a description of fees and compensation arrangements describing the manner and the 

nature of the work for which broker-dealers, investment advisers, and their associated 

persons are compensated; and 

• for broker-dealers, a description of whether the broker-dealer and its clearing firm are 

members of the Securities Investor Protection Corporation. 

B. Access to BrokerCheck and IAPD 

BrokerCheck and IAPD are Web-based disclosure systems that provide investors with 

access to the information described above. These databases help investors to investigate and 

evaluate broker-dealers, registered representatives, investment advisers, and investment adviser 

representatives. The Commission has stated that it “recognizes that the public’s ability to access 

information” through BrokerCheck, “whether to inquire about a registered person or formerly 

associated person, may serve to protect investors, the integrity of the marketplace, and the public 

interest.”17 Similarly, the Commission has noted that IAPD “allows the public to access the 

17 See Exchange Act Release No. 62476 (July 8, 2010) [75 FR 41254 (July 15, 2010)] (approving 

amendments to FINRA’s BrokerCheck disclosure rule (SR-FINRA-2010-012)). 
 

10

 

most recent Form ADV filing made by an investment adviser,”18 that a “client may use this 

disclosure [on Form ADV] to select his or her own adviser and evaluate the adviser’s business 

practices and conflicts on an ongoing basis,” and that ”the disclosure clients and prospective 

clients receive is critical to their ability to make an informed decision about whether to engage an 

adviser and, having engaged the adviser, to manage that relationship.”19

Both BrokerCheck and IAPD can be accessed from the Commission’s Web page at 

http://www.sec.gov/investor/brokers.htm. In addition, investors can access BrokerCheck at 

http://brokercheck.finra.org, through FINRA’s main Web page at http://www.finra.org, and 

through FINRA’s investor education foundation Web site at 

http://www.finrafoundation.org/resources/tools/index.htm. Investors can access IAPD at 

www.adviserinfo.sec.gov. Further, the OIEA-maintained investor education Web site, 

www.Investor.gov, provides links to both BrokerCheck and IAPD, and several OIEA investor 

education publications and outreach materials reference those Web sites as well. 

C. Overview of Sources of Publicly-Available Data Regarding Broker-Dealers, 

Investment Advisers, and their Associated Persons 

There is no single source of registration information regarding U.S. broker-dealers, 

investment advisers, and their associated persons. This reflects the fact that broker-dealers and 

investment advisers are regulated under two different regulatory regimes, with oversight shared 

among federal and state securities regulators and FINRA. The Commission has regulatory 

18 Investment Advisers Act Release No. 3110 n.123 (Nov. 19, 2010) [75 FR 77052, 77062 n.123 (Dec. 

10, 2010)] (proposing rules implementing amendments to the Advisers Act). 

19 Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234, 49234 (Aug. 12, 2010)] 

(adopting rule amendments to Form ADV). 
 

11

 

authority over broker-dealers, investment advisers that are required to register with the 

Commission, and their associated persons.20 Broker-dealers register with the Commission and 

the states in which they do business, and must also become members of an SRO, which, in most 

cases, is FINRA. A broker-dealer’s registered representatives (“registered representatives”) do 

not register with the Commission, but with the states in which they do business and with FINRA. 

The Commission regulates large advisory firms exclusively, while smaller advisory firms 

are overseen by the states in which they do business.21 The dividing line between larger and 

smaller advisory firms is based on the amount of assets managed by the investment adviser and 

currently stands at $25 million.22 Pursuant to an amendment to the Advisers Act and a 

Commission rule proposal, beginning July 21, 2011, investment advisers with assets under 

management (“AUM”) of over $100 million must register with the Commission, while 

investment advisers with less than $100 million in AUM register only with the states.23

Investment adviser representatives, like registered representatives, do not register with 

the Commission. Investment adviser representatives register only with the states. There is no 

SRO for investment advisers or investment adviser representatives. Advisory firms and their 

20 See Study on Investment Advisers and Broker-Dealers, as required by Section 913 of the Dodd-Frank 

Act (“Section 913 Study”) at 137, available at 

http://www.sec.gov/news/studies/2011/913studyfinal.pdf (discussing the disclosure requirements of 

Form ADV and Form BD). 

21 See the National Securities Market Improvement Act of 1996, Pub. L. No. 104-290, 110 Stat. 3438 

(1996). 

22 See Advisers Act Section 203A(a)(1)(A) [15 U.S.C. 80b-3a(a)(1)(A)]. 

23 See Investment Advisers Act Release No. 3110 (Nov. 19, 2010) [75 FR 77052 (Dec. 10, 2010)] 

(proposing rules implementing amendments to the Advisers Act). 
 

12

 

representatives may, however, be dually registered as broker-dealers and investment advisers or 

as registered representatives and investment adviser representatives. Fewer than 20% of 

registered broker-dealers were also registered as an investment adviser in 2010,24 and 

approximately 5% of SEC-registered advisory firms were registered as broker-dealers.25 

However, the approximately 611 firms dually registered with the Commission generally 

constitute very large firms in terms of assets and number of employees.26 As a result, most 

investment adviser representatives also are registered representatives. Of the approximately 

275,675 investment adviser representatives identified in IAPD in October 2010, approximately 

87.5% were registered as both investment adviser representatives and registered representatives, 

either for the same firm or multiple firms.27

Reflecting the differences in regulatory regimes, broker-dealers, investment advisers, and 

registered representatives and investment adviser representatives register using two separate 

systems. CRD, which is operated by FINRA, is the repository of registration and disciplinary 

information regarding broker-dealers and registered representatives. Electronic public access to 

certain CRD data is available through FINRA’s BrokerCheck Web site. FINRA maintains 

control over the data in those systems, as well as the design, functionality, and output of the 

BrokerCheck Web site. 

24 See Letter from FINRA (Nov. 3, 2010) (File No. 4-606) (regarding obligations of brokers, dealers, and 

investment advisers). 

25 Based on data obtained from IARD on Nov. 8, 2010. 

26 Id. 

27 Based on data obtained from FINRA on Nov. 3, 2010. 
 

13

IARD, which is owned by the Commission and operated by FINRA, is the repository of 

registration and disciplinary information about investment advisers and investment adviser 

representatives. Electronic public access to the information filed through IARD is available on 

the IAPD Web site. FINRA operates IARD and IAPD under contract with the Commission. 

States use CRD to register broker-dealers and registered representatives doing business in 

their state; and states register the investment advisers and investment adviser representatives they 

oversee, as required by state law, typically through IARD. 28 States generally do not post brokerdealer or investment adviser registration records on their Web sites, but many provide links to 

BrokerCheck and IAPD, and provide investors with copies of CRD records and IARD records 

upon request, on paper or electronically.29

IV. Broker-Dealer Registration and Disclosure

A. History of CRD and BrokerCheck 

Generally, brokers, who are engaged in the business of buying and selling securities for 

their customers’ accounts, and dealers, who are engaged in the business of buying and selling 

securities for their own account, are regulated under the Securities Exchange Act of 1934 (the 

“Exchange Act”).30 Congress amended the Exchange Act in 1938 to allow for private sector 

oversight of brokers and dealers, commonly referred to as self-regulation, which led to the 

 

28 Note, however, that Wyoming does not have a statutory requirement for investment adviser 

registration. 

29 For example, Oregon provides online access to information on investment advisers registered in the 

state. See the Oregon Division of Finance and Corporate Securities Web site at 

http://www4.cbs.state.or.us/ex/dfcs/dfcslic/adviser/. 

30 See Exchange Act Sections (3)(a)(4)(A) and (3)(a)(5)(A) [15 U.S.C. 78c(a)(4)(A) and 78c (a)(5)(A)]. 
 

14

 

creation of the National Association of Securities Dealers (“NASD”), now known as FINRA.31 

FINRA developed the CRD database in conjunction with NASAA to centralize registration for 

the broker-dealer industry.32 When implemented in 1981, CRD consolidated a multi-state, 

paper-based registration process into a single, nationwide filing process and computer system.33 

Information in CRD is obtained through forms (the “Uniform Forms”) that registered 

representatives, broker-dealers, and regulators complete as part of the securities industry 

registration and licensing process. Six different Uniform Forms are used to file information with 

CRD: (i) Form U4 (Uniform Application for Securities Industry Registration or Transfer); (ii) 

Form U5 (Uniform Termination Notice for Securities Industry Registration); (iii) Form U6 

(Uniform Disciplinary Action Reporting Form); (iv) Form BD (Uniform Application for BrokerDealer Registration), a Commission form; (v) Form BDW (Uniform Request for Broker-Dealer 

Withdrawal), also a Commission form; and (vi) Form BR (Uniform Branch Office Registration 

Form).34

31 On July 26, 2007, the Commission approved a proposed rule change by NASD to amend its Certificate 

of Incorporation to reflect its name change to FINRA, in connection with the consolidation of its 

member firm regulatory functions with NYSE Regulation, Inc. See Exchange Act Rel. No. 56145 (Jul. 

26, 2007) [72 FR 42190 (Aug. 1, 2007)]. For purposes of this study, the acronym “FINRA” will be 

used throughout except to refer to NASD rules and notices that FINRA continues to use. 

32 See NASAA’s Web site at http://www.nasaa.org/industry___regulatory_resources/CRD___IARD/. 

NASAA also includes hyperlinks to BrokerCheck and IAPD on its investor education Web page. See

NASAA’s investor education Web page at http://www.nasaa.org/investor_education/11080.cfm. 

33 See id. 

34 Information on the Uniform Forms is available at 

http://www.finra.org/industry/compliance/registration/crd/filingguidance/p005235. 
 

15

 

In 1988, FINRA established the Public Disclosure Program, the predecessor of 

BrokerCheck, to provide the public with information on the professional background, business 

practices, and conduct of FINRA members and their associated persons.35 In 1998, Internet 

access to registration data became available when FINRA began to provide public access to 

members’ registration information and their associated persons’ employment history through its 

Web site.36 In 1999, FINRA introduced “Web CRD,” which allowed the electronic filing of 

registration forms through its Web site.37 By 2002, more than 95% of the public inquiries to the 

Public Disclosure Program were received through the Internet.38 In response to this demand, 

FINRA proposed establishing a central electronic gateway to information about broker-dealers, 

which led to the creation of BrokerCheck, whose primary purpose is to help investors make 

informed choices about the individuals and firms with which they may wish to do business.39 In 

2006, Congress required FINRA to establish and maintain a system for collecting and 

maintaining registration information and a readily accessible electronic process to receive and 

35 See Exchange Act Release No. 25604 (April 20, 1988) [53 FR 14878 (April 26, 1988)] (Notice of 

Filing and Immediate Effectiveness of File No. SR-NASD-88-14). 

36 See Exchange Act Release No. 61927 (Apr. 16, 2010) [75 FR 21064 (Apr. 22, 2010)] (proposing 

amendments to FINRA’s BrokerCheck disclosure rule (SR-FINRA-2010-012)).

37 See FINRA’s Web site at www.finra.org/Industry/Compliance/Registration/CRD/index.htm. 

38 See NASD Notice to Members 02-74 (Nov. 2002) (requesting comment on Public Information Review 

Initiative). 

39 See Exchange Act Release No. 60462 (August 7, 2009) [74 FR 41470 (August 17, 2009)] (FINRA’s 

proposed rule change to its BrokerCheck disclosure rule (SR-FINRA-2009-050)). 
 

16

 

respond to inquiries about registration information, as well as adopt rules governing such 

inquiries and the type and scope of information to be provided in response.40

B. Data Available on BrokerCheck 

BrokerCheck provides public access to certain CRD registration data about brokerdealers and registered representatives.41 The information on BrokerCheck regarding registered 

representatives is derived from the information on the Uniform Forms, including Forms BD, 

BDW, U4, U5, U6, and BR. Information on formerly registered representatives is available for 

ten years after de-registration, and permanently for registered representatives who were the 

subject of a final regulatory action.42

FINRA Rule 8312 governs the information that FINRA releases to the public regarding 

broker-dealers and registered representatives and requires them to keep their registration data 

40 See Military Personnel Financial Service Protection Act, Pub. L. No. 109-290, 120 Stat. 1317 (2006). 

41 In October 2010, the BrokerCheck database covered approximately 637,347 registered representatives 

and approximately 4,698 registered broker-dealer firms (based on data obtained from FINRA on Oct. 

8, 2010). Of the firms, approximately 842, or approximately 18.4%, also were registered as 

investment advisers with the Commission or a state (based on data obtained from FINRA on Nov. 3, 

2010). There were approximately 12,440 formerly-registered broker-dealers in the database in 

October 2010 (based on data obtained from FINRA on Oct. 8, 2010). In October 2010, BrokerCheck 

displayed records for approximately 182,582 former registered representatives, with approximately 

32,000 of the records, or approximately 17.5%, permanently available (based on data obtained from 

FINRA on Oct. 8, 2010). In 2009, more than 20 million searches were conducted through 

BrokerCheck. 

42 A registered representative is subject to a final regulatory action if, among other things, he or she was: 

convicted of or pled guilty or no contest to certain crimes; subject to a civil injunction involving 

investment-related activity; found in a civil court to have been involved in a violation of investmentrelated statues or regulations, or named as a respondent or defendant in an investment-related, 

consumer initiated arbitration or civil lawsuit that alleged he or she committed a sales practice 

violation and resulted in an award or civil judgment against him or her. See Exchange Act Release 

No. 62476 (July 8, 2010) [75 FR 41254 (July 15, 2010)] (approving amendments to FINRA’s 

BrokerCheck disclosure rule (SR-FINRA-2010-012)). 
 

17

 

accurate and up-to-date.43 The rule has been revised several times in the past decade to increase 

the amount and type of information available to the public on BrokerCheck. For example, 

FINRA amended the rule in 2000 to continue to provide records about former registered 

representatives for two years after their association with a member firm had been terminated.44 

In 2007, the Commission approved FINRA’s amendment to Rule 8312 to provide for disclosure 

of examinations passed by registered representatives. FINRA also amended Rule 8312 to 

expand disclosure of arbitration awards to include those awards that historically were not 

reported because they fell below a specified dollar amount.45 These rule amendments 

established a threshold for publicly disclosing “historic” customer complaints at least two years 

old that either remained unresolved or settled for less than a specified dollar amount.46

In 2009, the Commission approved FINRA’s amendment to Rule 8312 to make available 

permanently in BrokerCheck information about former registered representatives who were the 

subject of a final regulatory action, such as an action brought by a federal, state, or foreign 

43 Broker-dealers must update CRD no later than thirty days after they learn that an update is required 

and in some instances, within ten days. See NYSE Rule 351(b) and NASD Rule 3070(b). 

44 See Exchange Act Release No. 42402 (Feb. 7, 2000) [65 FR 7582 (Feb. 15, 2000)] (approving 

amendments to NASD’s Public Disclosure Program (SR-NASD-99-45)). 

45 See Exchange Act Release No. 55127 (Jan. 18, 2007) [72 FR 3455 (Jan. 25, 2007)] (approving rule 

change relating to BrokerCheck disclosure (SR-NASD-2003-168)). 

46 Historic complaints are customer complaints that were reported on a uniform registration form that are 

more than two years old and that have not been settled or adjudicated and customer complaints, 

arbitrations, or litigations that have been settled for an amount less than the specified dollar amount 

(identified on the customer complaint question) and are therefore no longer reportable on a uniform 

registration form. See Exchange Act Release No. 62476 (July 8, 2010) [75 FR 41254 (July 15, 2010)] 

(approving amendments relating to BrokerCheck disclosure (SR-FINRA-2010-012)). 
 

18

 

financial regulatory authority, or an SRO.47 Effective November 2010, the Commission 

approved FINRA’s amendment to Rule 8312 to make BrokerCheck reports on former registered 

representatives publicly available for ten years after association with a member firm.48 

Previously, BrokerCheck reports on former registered representatives were made publicly 

available for only two years following their exit from the industry.49

Also in 2010, the Commission approved FINRA’s amendment to Rule 8312 to expand 

the information regarding former registered representatives that is available permanently on 

BrokerCheck.50 Prior to these amendments, criminal convictions and civil injunctions in 

connection with investment-related activities were disclosed for a two-year period following the 

termination of a registered representative’s association with a member firm. Following the 2010 

amendments, that information is disclosed permanently.51 The 2010 amendments also made 

47 See Exchange Act Release No. 61002 (Nov. 13, 2009) [74 FR 61193 (Nov. 23, 2009)] (approving rule 

change relating to BrokerCheck disclosure (SR-FINRA-2009-050)). 

48 In approving the FINRA rule filing, the Commission stated that it “will help members of the public to 

protect themselves from unscrupulous people.” See Exchange Act Release No. 62476 (July 8, 2010) 

[75 FR 41254, 41257 (July 15, 2010)] (approving amendments relating to BrokerCheck disclosure 

(SR-FINRA-2010-012)). In approving the proposed rule change, the Commission stated that “such 

information is relevant to investors and members of the public who wish to educate themselves with 

respect to the professional history of a formerly associated person. Formerly associated persons, 

although no longer in the securities industry in a registered capacity, may work in other investmentrelated industries, such as financial planning,” or “may seek to attain other positions of trust with 

potential investors. Disclosure of such person’s record, while he was in the securities industry via 

BrokerCheck should help members of the public decide whether to rely on his advice or expertise or 

do business with him.” Id. 

49 See Exchange Act Release No. 61002 (Nov. 13, 2009) [74 FR 61193 (Nov. 23, 2009)] (approving rule 

change relating to BrokerCheck disclosure (SR-FINRA-2009-050)). 

50 See supra note 48. 

51 Exchange Act Release No. 62476 (July 8, 2010) [75 FR 41254 (July 15, 2010)]. 
 

19

“historic” customer complaints publicly available through BrokerCheck in every case. Prior to 

those amendments, historic complaints were made publicly available through BrokerCheck only 

where: (i) they became historic complaints on or after March 19, 2007; (ii) the most recent 

historic complaint was less than ten years old; and (iii) the registered representative had a total of 

three or more disclosable regulatory actions, currently reported customer complaints, 

arbitrations, or litigations.52

Pursuant to the current version of FINRA Rule 8312, BrokerCheck provides the 

following information (subject to certain exceptions for personal and other information as set 

forth in the rule)53 with respect to current and former members, current associated persons, and 

persons associated with a member in the preceding ten years:

• any information reported on the most recently filed Form U4, Form U5, Form U6, 

Form BD, and Form BDW; 

• currently approved registrations; 

• summary information about certain arbitration awards against a member involving a 

securities or commodities dispute with a public customer; 

• the most recently submitted comment, if any, provided to FINRA by the person who 

is covered by BrokerCheck, in the form and in accordance with the procedures 

established by FINRA, for inclusion with the information provided through 

BrokerCheck (only comments that relate to the information provided through 

BrokerCheck are included); 

• information as to qualification examinations passed by the person and date passed 

(FINRA does not release information regarding examination scores or failed 

examinations); 

• in response to telephonic inquiries via the BrokerCheck toll-free telephone listing, 

whether a particular member is subject to the provisions of NASD Rule 3010(b)(2) 

(FINRA’s taping rule); 

 

52 Exchange Act Release No. 62476 (July 8, 2010) [75 FR 41254 (July 15, 2010)]. 

53 See FINRA Rule 8312(d). 
 

20

• historic complaints (i.e., the information last reported on Uniform Forms relating to 

customer complaints that are more than two years old and that have not been settled 

or adjudicated, and customer complaints, arbitrations or litigations that have been 

settled for an amount less than $10,000 prior to May 18, 2009 or an amount less than 

$15,000 on or after May 18, 2009 and are no longer reported on a Uniform Form), 

provided that any such matter became a Historic Complaint on or after August 16, 

1999; and 

• the name and succession history for current or former members.54

In addition, BrokerCheck provides the following information (subject to certain 

exceptions for personal and other information as set forth in the rule)55 with respect to persons 

who were formerly associated with a member, but who have not been associated with a member 

within the preceding ten years, and (A) were ever the subject of a final regulatory action as 

defined in Form U4 that has been reported to CRD on a Uniform Form; or (B) were registered 

with FINRA on or after August 16, 1999, and any of the following applies, as reported to CRD 

on a Uniform Form: (i) was convicted of or pled guilty or nolo contendere to a crime; (ii) was 

the subject of a civil injunction in connection with investment-related activity or a civil court 

finding of involvement in a violation of any investment-related statute or regulation; or (iii) was 

named as a respondent or defendant in an investment-related, consumer-initiated arbitration or 

civil litigation which alleged that the person was involved in a sales practice violation and which 

resulted in an arbitration award or civil judgment against the person: 

• information regarding the event(s) enumerated above or as reported on a Uniform 

Form; 

• administrative information, including employment history and registration history 

derived from information reported on a Uniform Form; 

 

54 See FINRA Rule 8312(b). 

55 See FINRA Rule 8312(d). 
 

21

• the most recently submitted comment, if any, provided to FINRA by the person who 

is covered by BrokerCheck, in the form and in accordance with the procedures 

established by FINRA, for inclusion with the information provided through 

BrokerCheck (only comments that relate to the information provided through 

BrokerCheck are included); and 

• information as to qualifications examinations passed by the person and date passed 

(FINRA does not release information regarding examination scores or failed 

examinations).56

Not all information in CRD is disclosed to the public through BrokerCheck. The 

following CRD information is not made publicly available on BrokerCheck: 

• Reasons and Comments Related to Termination. In situations where a broker-dealer 

terminates a registered representative, BrokerCheck reports exclude the reason for the 

termination and any comments from the former registered representative regarding 

the termination, although this information is reported on Form U5. FINRA also 

excludes from BrokerCheck, generally, information on Form U4 for registered 

representatives who have terminated registration more than ten years ago.57

• Formerly Reportable Information. Certain information that was, but is no longer 

required to be, reported through the registration and licensing process is not disclosed 

through BrokerCheck. This information includes, for example, judgments and liens 

originally reported as outstanding that have been satisfied and bankruptcy 

proceedings filed more than ten years ago. 

• Examination Details. Scores on industry qualification examinations, and failed 

examinations, are also excluded from BrokerCheck reports, although BrokerCheck 

displays industry examinations that a registered representative has passed.58

• Previous Filings. BrokerCheck provides only the most recent filings by brokerdealers and their associated persons; it does not provide access to previous filings. 

• Discretionary Disclosure. FINRA, on a case-by-case basis, reserves the right to 

 

56 See FINRA Rule 8312(c). 

57 See FINRA Rule 8312(b)(1). 

58 FINRA has stated that it excludes such information because the passing grade varies from examination 

to examination and can change over time, and that examination scores are not designed to predict an 

individual’s job performance or compliance record. Id.
 

22

exclude information that contains confidential customer information, offensive or 

potentially defamatory language or information that raises significant identity theft or 

privacy concerns that are not outweighed by investor protection concerns. Also, in 

certain limited circumstances, FINRA’s policy allows for information to be expunged 

from CRD, most often pursuant to a court order. 

• Personal Information. FINRA does not include Social Security numbers, home 

addresses, or physical descriptions in BrokerCheck reports. 

• Certain Criminal Charges. Criminal charges that did not result in convictions and 

certain other actions that did not lead to an award or finding against the registered 

representative, for whatever reason, are not disclosed through BrokerCheck. 

C. BrokerCheck Format and Usage 

BrokerCheck’s format allows users to search by name or registration number for a 

registered representative or broker-dealer. Results are displayed in a one-page summary; more 

detailed information is available as well. An investor who accesses BrokerCheck seeking 

information about a broker-dealer would be presented with the following information in the 

heading for the summary report: the name of the firm; its registration number or numbers; the 

address of its main office; its mailing address; and its business telephone number. An investor 

who accesses BrokerCheck for information on an individual registered representative would be 

presented with the following information in the heading for the summary report: the name of the 

individual; the individual’s registration number; the name and address of the firm with which the 

individual is currently employed and registered; and the length of time the individual has been 

registered with that firm. 

In 1999, a year after FINRA began making records available on its Web site, FINRA 

received more than one million inquiries, and by 2002, it was fielding more than two million 
 

23

inquiries a year.59 Usage has increased since BrokerCheck was deployed in March 2007. More 

than 20 million searches were conducted on the BrokerCheck Web site in 2009, with 

approximately 18.5 million summary records viewed and approximately 3.8 million requests for 

detailed reports on a registered representative or a broker-dealer.60 However, FINRA is unable 

to determine the number of unique visitors to BrokerCheck because BrokerCheck does not use 

persistent “cookies” – small data files that would allow it to recognize repeat visitors. FINRA is 

further unable to identify the percentage of visitors to the BrokerCheck Web site that are 

individual investors, regulators, or brokerage industry members.61

V. Investment Adviser Registration and Disclosure

A. History of IARD and IAPD 

Investment advisers receive compensation for providing advice to others about investing 

in securities. 62 Investment advisers use Form ADV under the Investment Advisers Act of 1940 

(“Advisers Act”) to apply for registration with the Commission or with state securities 

authorities.63 The Commission adopted Form ADV in 1954 and has amended the form several 

times since then.64 For example, in 1985, the Commission, together with NASAA, developed a 

 

59 Based on data obtained from FINRA on Nov. 3, 2010. 

60 Based on data obtained from FINRA on Oct. 8, 2010. 

61 Although the BrokerCheck Web site includes a link to a voluntary survey that visitors may access to 

provide demographic data to FINRA for its internal use, it is unclear whether, and how many, visitors 

to the BrokerCheck Web site actually access and respond to the survey. 

62 See Advisers Act Section 202(a)(11) [15 U.S.C. 80b-2(a)(11)]. 

63 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 n.5 (Aug. 12, 2010)] 

(adopting rule amendments to Form ADV). 

64 See Investment Advisers Act Release No. 73 (June 25, 1954). 
 

24

 

new version of Form ADV – the “Uniform Application for Investment Adviser Registration” – to 

serve as the investment adviser registration form for all jurisdictions requiring registration.65 

This uniform Form ADV is the basis of the form that investment advisers use today.66

Amendments to Form ADV in 1979 promulgated the so-called “brochure rule” that 

currently requires certain investment advisers subject to registration with the Commission under 

the Advisers Act to furnish clients and prospective clients with a written document – the 

brochure – and one or more brochure supplements, containing the information required by Part 2 

of Form ADV.67 The brochure rule requires investment advisers to deliver the brochure directly 

to clients and prospective clients before or at the time of entering into an investment advisory 

contract, and each year thereafter to provide clients with either (i) a copy of the current (updated) 

brochure, or (ii) a summary of material changes to the brochure that includes an offer to provide 

a copy of the current brochure.68 The Commission recently changed the presentation 

requirements of the brochure from a check-the-box type format to a narrative format designed to 

provide investors with clearly written, meaningful, current disclosure of the business practices, 

conflicts of interest, and background of the investment adviser.69

65 See Investment Advisers Act Release No. 991 (Oct. 15, 1985) [50 FR 42903 (Oct. 23, 1985)]. The 

uniform Form ADV became effective on January 1, 1986.

66 Id. 

67 See Investment Advisers Act Release No. 664 (Jan. 30, 1979) [44 FR 7370 (Feb. 7, 1979)]. See also

Rule 204-3(a) under the Advisers Act [17 CFR 275.204-3(a)]. 

68 See Rule 204-3 under the Advisers Act [17 CFR 275.204-3]. 

69 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 n.5 (Aug. 12, 2010)] 

(adopting rule amendments to Form ADV). 
 

25

 

Currently, investment advisers subject to registration under the Advisers Act are required 

to file Form ADV (including the Part 2A brochure – but not the Part 2B brochure supplement)70

electronically through IARD. Prior to 1996, most investment advisers were required to register 

with the Commission as well as with each state in which they did business, using paper-based 

forms. The National Securities Market Improvement Act of 1996 (“NSMIA”) eliminated this 

system of dual registration and consolidated oversight.71 In most cases, NSMIA mandated that 

oversight of larger advisory firms be left exclusively to the Commission, with smaller firms to be 

overseen by the states in which they do business.72 Under NSMIA, the dividing line was based 

on the amount of assets managed by the adviser, and was set at $25 million.73 Under the DoddFrank Act, that threshold will rise to $100 million on July 21, 2011.74

NSMIA also authorized the Commission to establish an electronic filing system for 

investment advisers, to require advisers to pay the costs associated with the system, and to 

70 As discussed in greater detail in Section V.B below, the brochure supplement describes the 

educational background, business experience, and disciplinary history (if any) of specified 

individuals providing advisory services to a particular client.

71 Pub. L. No. 104-290, 110 Stat. 3438 (1996). NSMIA is codified in relevant part as Section 203A of 

the Advisers Act [15 U.S.C. 80b-3a]. 

72 The Commission and the states retained general antifraud enforcement authority over the advisers that 

were not registered with them. 

73 Advisers Act Section 203A(a)(1)(A) [15 U.S.C. 80b-3a(a)(1)(A)]. 

74 See Section 410 of the Dodd-Frank Act; Advisers Act Section 203A [15 U.S.C. 80b-3]; Investment 

Advisers Act Release No. 3110 (Nov. 19, 2010) [75 FR 77052 (Dec. 10, 2010)] (proposing rules 

implementing amendments to the Advisers Act to effectuate certain provisions of the Dodd-Frank Act, 

including requiring, among other things, hedge funds and other private funds to register with the 

Commission). 
 

26

 

provide investors with a readily accessible database of information about investment advisers.75 

Under this authority, the Commission adopted a rule in 2000 requiring advisers to register 

electronically by filing through IARD, starting in 2001.76 The Commission contracted with 

FINRA to operate IARD, citing its technical expertise in running Web CRD.77 FINRA 

continues to operate IARD under contract with the Commission. The Commission, in 

consultation with the state securities authorities with respect to Uniform Forms, retains decisionmaking authority with respect to expanding IARD and the information that is collected by this 

system. The Commission recently has adopted a significant revision to the core information 

collection documents for investment advisers,78 and is preparing to implement additional 

changes to the investment adviser registration regime pursuant to the Dodd-Frank Act.79

IAPD has been in operation since 2001 for investment advisory firms. IAPD displays 

records for SEC- and state-registered advisers, and was expanded in mid-2010 to include 

75 Pub. L. No. 104-290, 110 Stat. 3438 (1996). See also Investment Advisers Act Release No. 1897 

(Sept. 12, 2000) [65 FR 57438 (Sept. 22, 2000)] (adopting rules and rule amendments requiring 

electronic filing by investment advisers).

76 Investment Advisers Act Release No. 1897 (Sept. 12, 2000) [65 FR 57438, 57445 (Sept. 22, 

2000)](adopting rules and rule amendments requiring electronic filing by investment advisers) (stating 

that the amendments were “necessary” to, among other things, “develop a database of information 

about advisers that is easily accessible to investors”). 

77 See IARD Web site at http://www.iard.com/WhatIsIARD.asp. 

78 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 (Aug. 12, 2010)] 

(adopting rule amendments to Form ADV). 

79 See Investment Advisers Act Release No. 3110 (Nov. 19, 2010) [75 FR 77052 (Dec. 10, 2010)] 

(proposing rules implementing amendments to the Advisers Act to effectuate certain provisions of the 

Dodd-Frank Act, including requiring, among other things, managers of hedge funds and other private 

funds to register with the Commission). 
 

27

 

investment adviser representatives.80 IAPD also contains information on formerly registered 

advisers and investment adviser representatives. In November 2010, the system was modified to 

retain information about advisory firms and investment adviser representatives that de-registered 

in the past ten years, mirroring changes, approved a few months earlier, to BrokerCheck for 

former registered representatives.81 Previously, IAPD displayed data on advisory firms for two 

years after their de-registration.

In the second half of 2010, there were approximately 11,889 SEC-registered investment 

advisers and approximately 14,688 state registered investment advisers on IAPD.82 The Staff 

anticipates that approximately 4,100 SEC-registered advisers will shift to state oversight once the 

Dodd-Frank Act’s higher threshold for SEC oversight of advisers takes effect on July 21, 2011. 

A Dodd-Frank Act requirement for registration of certain private investment fund managers is 

expected to add approximately 750 SEC-registered advisers, for a net reduction of approximately 

3,350 SEC-registered advisers. 

80 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 (Aug. 12, 2010)] 

(adopting amendments to Form ADV). 

81 Id. 

82 Based on data obtained from IARD on Nov. 8, 2010. SEC registration data are as of Nov. 1, 2010. 

State registration data are as of July 1, 2010. 
 

28

 

B. Data Available on IARD and IAPD 

Although IARD was modeled on CRD,83 the systems differ in design to accommodate 

the fact that advisory firms register using different forms than broker-dealers. The investment 

adviser forms that are on IAPD are Form ADV and Form ADV-E.84 Investment adviser 

representative information on IAPD is summarized from various state sources, including: 

• Forms U4, U5, and U6; 

• current registration status and effective date of investment adviser representative 

registrations from IARD and /or CRD; 

• investment adviser representative comments submitted to FINRA regarding 

information in IAPD; 

• any applicable qualification examinations passed by investment adviser 

representatives; and 

• certain designations (e.g., Certified Financial Planner, Certified Financial Analyst) 

reported to FINRA by the applicable designating authority. 

Investment advisers register with the Commission by filing the two-part Form ADV, and 

withdraw from registration by filing a Form ADV-W. Regulators use Part 1 of Form ADV to 

process registrations and manage regulatory and examination programs.85 Part 2A of Form 

ADV, known as the “brochure,” is intended for advisory clients and also provides information 

83 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 (Aug. 12, 2010)] 

(adopting amendments to Form ADV).

84 Form ADV-E is the form that is required to be completed by investment advisers that have custody of 

client funds or securities and that are subject to an annual surprise examination. 

85 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 (Aug. 12, 2010)] 

(adopting amendments to Form ADV). 
 

29

 

used by the Commission’s examination program.86 Part 2B requires investment advisers to 

provide clients and prospective clients with a “brochure supplement” describing the educational 

background, business experience, and disciplinary history (if any) of specified individuals 

providing advisory services to a particular client.87

Investment advisers must update Part 1 of their Form ADV at least annually, within 

ninety days of their fiscal year end, or more often as needed to report certain disciplinary actions 

or specified changes to the adviser’s services or contact information.88 Part 1 of Form ADV uses 

a check-the-box, multiple-choice, question-and-answer format to describe the adviser’s business. 

It provides details on persons who own and control the advisory firm, including whether the firm 

or any of its current personnel has been disciplined in the past ten years in any criminal, civil, or 

regulatory actions, or in foreign or military courts.89 In 2000, the Commission substantially 

amended Part 1 of the form to accommodate electronic filing,90 and divided it into two sections, 

with the first to be completed by all investment advisers and the second by state registered 

advisers.91

For advisory firms, the IAPD report generally displays the firm’s completed Form ADV. 

Nearly all of the information collected on Form ADV with respect to investment advisers is 

86 Id. 

87 Id. 

88 Id. 

89 Investment Advisers Act Release No. 1897 (Sept. 12, 2000) [65 FR 57438, 57445 (Sept. 22, 2000)]. 

90 Id.

91 Id.
 

30

 

made publicly available through IAPD.92 The first item on Form ADV includes certain 

identifying information, including, for example: the full legal name of the firm; its registration 

number; its address; the days and times of normal business operations; whether it has a Web 

address; and whether it is registered with any foreign regulatory authority. The second item on 

the form covers the firm’s U.S. registrations and notice filings. Item 3 on the form covers how 

the firm is organized and when its fiscal year ends. Item 4 covers whether the firm is a successor 

to a previously registered investment adviser. Item 5 contains information about the adviser’s 

business, such as the number of employees and clients, the types of clients, the amount of assets 

the firm manages, and compensation agreements. 

Item 6 covers other business activities of the adviser, including broker-dealer operations. 

Item 7 covers financial industry affiliations, such as with another investment adviser or brokerdealer. Item 8 covers the firm’s participation or interest in client transactions. Item 9 covers 

how the firm handles custody of customers’ cash or securities. Item 10 identifies who controls 

the adviser. Item 11 covers the adviser’s regulatory and disciplinary history. Item 12 applies if 

the firm qualifies as a small business. Investors may click through each item to get to the next 

item of the form or may navigate to specific items of the form through a menu located on each 

page; there is no summary of the information. 

Part 2A of Form ADV (the “brochure”) requires some of the same information contained 

in Part 1, in a narrative format, as well as information on business practices, fees, and conflicts of 

interest that the investment adviser may have with clients. As discussed, the Commission 

92 Two categories of information filed with IARD but excluded from IAPD are historical filings and 

withdrawal forms. An investment adviser’s registration status, however, does reflect withdrawal form 

filings. In addition, certain personally identifiable information such as Social Security numbers and 

private residence addresses of investment adviser representatives are not available on IAPD. 
 

31

 

requires investment advisers to deliver the brochure directly to clients and prospective clients 

before or at the time of entering into an investment advisory contract, and each year thereafter to 

provide clients with either a copy of the current (updated) brochure, or a summary of material 

changes to the brochure that includes an offer to provide a copy of the current brochure.93 

Because material changes are required to be communicated to investors, they need not access 

IAPD solely to apprise themselves of such developments. 

Under 2010 amendments to Form ADV and related rules, most SEC-registered advisers 

are required to have a Part 2A brochure filed electronically by April 1, 2011.94 The brochures, 

which will use a standardized format to “facilitate investors’ comparison of multiple advisers,” 

will be available in IAPD as PDF documents.95 Brochures already are posted on IAPD for 

advisers that file them electronically on a voluntary basis. 

The 2010 amendments also required changes to the content of brochures themselves, 

specifying eighteen items that must be presented in a plain English, narrative format.96 They are: 

• Item 1. Cover Page 

• Item 2. Material Changes 

• Item 3. Table of Contents 

• Item 4. Advisory Business 

• Item 5. Fees and Compensation 

93 See Rule 204-3 under the Advisers Act [17 CFR 275.204-3]. 

94 See Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 (Aug. 12, 2010)] 

(adopting amendments to Form ADV). 

95 Id. 

96 Id. 
 

32

 

• Item 6. Performance-Based Fees and Side-by-Side Management 

• Item 7. Types of Clients 

• Item 8. Methods of Analysis, Investment Strategies and Risk of Loss 

• Item 9. Disciplinary Information 

• Item 10. Other Financial Industry Activities and Affiliations 

• Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal 

Trading 

• Item 12. Brokerage Practices 

• Item 13. Review of Accounts 

• Item 14. Client Referrals and Other Compensation 

• Item 15. Custody 

• Item 16. Investment Discretion 

• Item 17. Voting Client Securities 

• Item 18. Financial Information 

The Commission’s 2010 rule amendments require investment advisers to provide clients 

with a Part 2B brochure supplement detailing the educational background, business experience, 

and disciplinary history (if any) of specified individuals providing advisory services to a 

particular client.97 Investment advisers registered with the Commission are not required to file 

Part 2B brochure supplements electronically through IARD, and the brochure supplements are 

not available on IAPD unless voluntarily filed through IARD. 

97 Id. 
 

33

 

C. IAPD Format and Usage 

Just as BrokerCheck allows users to search for a broker-dealer or a registered 

representative, IAPD permits users to search for an advisory firm or an investment adviser 

representative by name or registration number. Advisory firm searches display complete 

registration data on Part 1 of the firm’s Form ADV and the brochure or brochures the adviser has 

filed. In contrast, IAPD reports on investment adviser representatives use the same format as 

BrokerCheck, providing a summary and a more detailed report. A link to BrokerCheck is 

provided on the IAPD Web site for dually registered investment adviser representatives, whose 

records are contained in both databases. 

The summary page on IAPD for investment adviser representatives contains the same 

categories of information that appear on BrokerCheck for registered representatives – current 

employer, qualifications, registration and employment history, and disclosure events – presented 

in a slightly different format. The IAPD summary shows if the investment adviser representative 

also is registered as a registered representative, and links to BrokerCheck. 

In the second quarter of 2010, there were approximately 188,572 visits to IAPD. For 

2009, visits totaled approximately 1.31 million. This was an increase from approximately 1.16 

million in 2008.98 The Commission is unable to identify the number of unique visitors to IAPD, 

or the type of visitor, because IAPD does not place “cookies” on the computers of those using 

IAPD.99

98 Based on data obtained from FINRA on July 28, 2010. 

99 See IARD Web site at http://www.iard.com. 
 

34

VI. Comparative Nature of Information Disclosed in BrokerCheck and IAPD

There are conceptual and operational differences in the way that information is made 

publicly available to investors regarding broker-dealers and investment advisers and their 

associated persons, depending on whether data about the broker-dealer, registered representative, 

investment adviser, or investment adviser representative are contained in BrokerCheck, in IAPD, 

or both.100 For example, BrokerCheck information generally is derived from data obtained 

through Forms – BD, BDW, U4, U5, U6, and BR – that broker-dealers, registered 

representatives, and regulators complete as part of the securities industry registration and 

licensing process and currently file through CRD. This generally includes information about 

current and former members, current registered representatives, and persons who were associated 

with a member in the preceding ten years, and information about persons who were formerly 

associated with a member, but who have not been associated with a member within the preceding 

ten years, but who nevertheless meet certain criteria.101 FINRA is not required to make publicly 

available through BrokerCheck all CRD information submitted by broker-dealers and registered 

representatives. 

IAPD essentially reproduces all of the information contained in the Form ADV and filed 

through IARD. This broad disclosure regime includes, among other things, narrative brochures 

that address the adviser’s business and conflicts of interest, details about the persons who own 

 

100 The Staff recognizes that additional investor education and promotion of BrokerCheck and IAPD may 

be required to encourage investors to use those two systems. Further investigation into investor usage 

of BrokerCheck and IAPD is anticipated in connection with the Commission’s study pursuant to 

Section 917 of the Dodd-Frank Act, regarding financial literacy among investors. See also Section 

913 Study. 

101 See supra Section IV.B. 
 

35

 

and control the advisory firm, including whether the firm or any of its current personnel has been 

disciplined in the past ten years in any criminal, civil, or regulatory actions, or in foreign or 

military courts as well as pending disciplinary events.102 Investment advisers are required to 

deliver the brochure and any brochure supplements directly to their clients and prospective 

clients before or at the time of entering into an investment advisory contract, and annually 

thereafter to provide clients with either a copy of the current (updated) brochure, or a summary 

of material changes to the brochure that includes an offer to provide a copy of the current 

brochure.103 Moreover, because material changes to the brochure are required to be 

communicated to existing and prospective advisory clients, those persons need not access IAPD 

to learn of such changes. The Staff has attempted to take into account the nature of these two 

disclosure regimes in formulating its recommendations. 

102 Note that BrokerCheck and IAPD “may disclose slightly different information regarding [h]istoric 

[c]omplaints of those financial services professionals that are dually registered as brokers and 

investment advisers.” Exchange Act Release No. 61927 n.20 (Apr. 16, 2010) [75 FR 21064 (Apr. 22, 

2010)] (proposing amendments to FINRA’s BrokerCheck disclosure rule and discussing IAPD-I, the 

database that provides public registration and licensing information about natural persons who are 

registered as investment advisers with the states (SR-FINRA-2010-012)). For dually registered firms 

and representatives, the BrokerCheck report shows that information about the firm or the individual is 

available through IAPD, and the IAPD report shows that information about the firm or individual is 

available through BrokerCheck. In either case, the report includes a link to the other database. 

Historic customer complaints for investment adviser representatives that are made publicly available 

on IAPD date back to March 18, 2002, which is the date that IARD began accepting filings for 

investment adviser representative registration. See Exchange Act Release No. 61927 n.20 (Apr. 16, 

2010) [75 FR 21064 (Apr. 22, 2010)]. BrokerCheck makes publicly available historic complaints, 

including those archived after the implementation of Web CRD on August 16, 1999. 

103 See Rule 204-3 under the Advisers Act [17 CFR 275.204-3]. 
 

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VII. Recommendations

The Staff makes the following recommendations. In the near-term, i.e., in the eighteenmonth implementation period, the Staff recommends: (1) unifying BrokerCheck and IAPD 

search results; (2) adding a ZIP code search or other indicator of location function to 

BrokerCheck and IAPD; and (3) adding educational content to BrokerCheck and IAPD. The 

Staff also recommends that, subsequent to the eighteen-month implementation period, 

Commission staff and FINRA continue to analyze, including through investor testing, the 

feasibility and advisability of expanding BrokerCheck to include information currently available 

in CRD, as well as the method and format of publishing that information; and that Commission 

staff continue to evaluate expanding IAPD content and the method and format of publishing that 

content, including through investor testing. 

A. Near-Term Recommendations 

The near-term recommendations, as described in greater detail below, involve unifying 

BrokerCheck and IAPD search results, adding a ZIP code search or other indicator of location 

function to BrokerCheck and IAPD, and adding educational content to BrokerCheck and IAPD. 

1. Further Centralizing Access to CRD and IARD Through Use of a Unified Search 

Function

As noted earlier, the primary advantage of centralized access to registration information 

is that all of the data in the two systems would be in one place, making it easier for investors to 

obtain useful data. As described above, the current disclosure system comprises two distinct 

registration databases, requiring investors to know which database to search: BrokerCheck or 
 

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IAPD.104 For investors who do not know whether their financial services provider is registered 

as a broker-dealer or an investment adviser, knowing where to conduct a background search may 

be problematic.105 Moreover, not all financial services providers are required to register, 

including some service providers in the mortgage brokerage, banking, futures trading, or 

insurance industries. Some are exempt from registration or operate outside the Commission’s 

oversight. Centralizing access would make it more likely that investors could find data about a 

financial services provider who at any time was registered as a registered representative or 

investment adviser representative, whether or not they knew the provider’s registration status. 

For the reasons above, a single system for searching for data on broker-dealers, 

investment advisers, and their associated persons may yield benefits in the long-term. However, 

given the time constraints imposed by the Dodd-Frank Act, maintaining the current separate 

databases, but unifying the search results, seems more feasible in the near-term. This approach 

would maintain the current CRD and IARD databases and the current BrokerCheck and IAPD 

Web sites, but each system would be modified to search the other’s database and to return results 

from both.106

104 This has led some to call for “a unified database that could track individuals,” including those who are 

dually registered. See Angela A. Hung et al., Investor and Industry Perspectives on Investment 

Advisers and Broker-Dealers, at 79 (RAND Institute for Civil Justice 2008) (the “RAND Report”). 

105 The RAND Report found investors typically fail to distinguish between broker-dealers and investment 

advisers along the lines defined by federal regulations. 

106 As discussed, currently, for dually registered firms and representatives, the BrokerCheck report shows 

that information about the firm or the individual is available through IAPD, and the IAPD report 

shows that information about the firm or individual is available through BrokerCheck. In either case, 

the report includes a link to the other database. 
 

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There are several benefits to investors from unifying search results from the BrokerCheck 

and IAPD systems. It would eliminate the possibility that an investor would search for records 

about a broker-dealer or investment adviser, but fail to locate them because the investor chose 

the wrong database to search. It would also make the search process more efficient by 

eliminating the need to search two separate databases. Further, there would be no need to 

develop or promote a new Web site, making this approach less costly than the second option 

described below. Finally, the current level of usability would be maintained. 

The Staff also considered two other approaches: (i) collapsing the two systems into a 

single public database; and (ii) creating an additional third Web site that would serve as a search 

portal for the systems. In the near-term, given the eighteen-month implementation period and 

other considerations discussed below, the Staff instead recommends maintaining the current 

separate databases but unifying the search results. 

Collapsing the two systems. For the reasons above, a single system for searching for data 

about financial services providers may have long-term benefits. Creating a single public 

disclosure database by merging BrokerCheck and IAPD would facilitate investor access to data 

regarding financial services providers registered with the Commission. The advantage of this 

approach, as with our recommendation of a unified search function, is that it could make it easier 

for investors to access information because all of the information would be housed in a single 

database with a single point of access. 

However, this approach presents significant issues that could be difficult to resolve 

expeditiously. Those issues include determining the potential costs and benefits of merging the 

two databases, the impact of such a merger on database ownership and the need for agreement 
 

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among FINRA, NASAA, and the Commission, and the effect of a merger on the usability of a 

combined system. In addition, this option could entail potentially significant costs to re-engineer 

and redesign the sites and to market the new database. 

Creating a third Web site portal. Another approach would be to maintain BrokerCheck 

and IAPD in their current forms, but create a new Web site that would provide a single public 

disclosure gateway to them. This portal would not require users to know whether they should 

use BrokerCheck or IAPD. The creation of a third, separate route to the existing databases might 

pose fewer issues than an outright merging of BrokerCheck and IAPD because each system 

would remain independent. However, developing a new Web site would take additional 

resources, further time to acclimate investors to the new Web site as a source of information 

(particularly given the widespread use of BrokerCheck), and there would be questions to resolve, 

such as who would own and maintain the new Web site. 

2. Add Search by ZIP Code or Other Indicator of Location

BrokerCheck and IAPD are designed to search for an individual or firm by name or 

registration number, which is useful only to investors who already have a broker-dealer or 

investment adviser, or who wish to research a particular person or firm, for example, one that has 

“cold-called” or otherwise solicited, or been referred to, them.107 The systems are not, however, 

 

107 According to one recent survey, most people searching for a financial services firm or a financial 

services provider rely on referrals from family members, friends, or professionals. See Angela A. 

Hung et al., Investor Knowledge and Experience with Investment Advisers and Broker-Dealers

(RAND Institute for Civil Justice 2010). The same survey found less than 10% of those surveyed use 

the Internet to find a financial services firm and less than one percent use the Internet to find a 

financial services provider. Id. at 42. While family members, friends, and professionals can serve as 

valuable sources of information, the Staff believes that investors should evaluate thoroughly the 

background of any financial services provider that they use or plan to engage. 
 

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as useful for more general research about financial services providers. For example, they do not 

easily permit investors to locate and compare nearby financial services providers because they 

lack a function that would allow investors to search for a broker-dealer or investment adviser by 

ZIP code or other indicator of location. A search by ZIP code function might be helpful to 

investors who are seeking to hire a financial services provider by identifying those financial 

services providers who are located close enough to visit in person, or to compare an individual 

they have hired already with others nearby providing similar services. The Internet is now 

commonly used as a research tool, with approximately 58% of adults conducting research online 

about the products and services they buy, 108 a level that rises to approximately 88% for those 

with a household income of $75,000 or more.109 However, the Internet is not commonly used to 

assist in the search for a financial services provider.110

Adding a search by ZIP code function to BrokerCheck and IAPD may raise concerns, 

however. One concern is that providing the names of financial firms or financial services 

providers on a regulatory site would be viewed by investors as an endorsement of the individuals 

or firms identified by the search. To help address this concern, a prominent disclaimer could be 

108 See Jim Jansen, Online Product Research (Pew Internet & American Life Project at 2) (Sept. 29, 

2010) (documenting the percentage of Americans who have researched a product or service online). 

109 Id. at 4. 

110 One way of locating information on the Internet via a search engine is to use a “local qualifier” such 

as a ZIP code. For example, some major financial institutions provide ZIP code search tools on their 

proprietary Web sites to help direct clients and prospective clients to local offices or affiliated 

financial services providers. Some financial trade associations also offer connections by ZIP code to 

certain credentialed financial services providers that they represent. Another category of financial 

search tools is provided by commercial Web sites that offer to link investors to the type of qualified 

financial services provider they are seeking based on ZIP code. These various ZIP code search tools, 

however, generally do not appear to provide the depth of information and detailed disclosures 

contained in BrokerCheck or IAPD. 
 

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added to inform users that search results do not constitute an endorsement. A second concern is 

that a ZIP code search function could encourage third parties to extract data from BrokerCheck 

and IAPD for repackaging and sale. While the Staff does not necessarily oppose the widespread 

dissemination of registration information, some methods that third parties use to extract data, 

such as data-scraping,111 can interfere with the efficient performance of the systems. Although 

data-scraping and other technology issues related to a search by ZIP code function pose 

challenges, these obstacles do not appear to be insurmountable because technologies and 

protocols currently exist that are widely used by commercial firms to prevent the unauthorized 

acquisition of information, proprietary or otherwise. Implementing a search by ZIP code 

function for BrokerCheck would require FINRA to make programming changes to BrokerCheck; 

adding this function to IAPD would require programming changes with Commission 

authorization. 

3. Add Educational Content

The Staff recommends that the BrokerCheck and IAPD Web sites be modified to add 

online educational materials, including links and definitions of terms that may be unfamiliar to 

individual investors. The definitions could be displayed through a rollover, hyperlinks, or other 

technology. Currently, BrokerCheck and IAPD both contain glossaries with definitions of terms 

 

111 Data- or screen-scraping is the process of acquiring data displayed onscreen by capturing the 

displayed text, either manually with the “copy” command or via software. See, e.g., Christopher 

Vidiksis, How to Buffer Your Way Out of a Scrape: Potential Abuse of the Cartoon Network v. 

Cablevision Decision, 4 Brook. J. Corp. Fin. & Com. L. 139, 140 n.32 (Fall 2009) (describing 

variations of screen-scraping). Screen-scraping typically occurs when software developers and data 

aggregators employ the use of programs that rove the Internet and programmatically evaluate digitally 

displayed information in order to extract from it the specific information requested by a third party. 

Id. at 147. See also Julia Angwin and Steve Stecklow, ‘Scrapers’ Dig Deep for Data on Web, Wall 

St. J. (Oct. 12, 2010). 
 

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used on the sites. For example, the BrokerCheck glossary includes terms that frequently appear 

on BrokerCheck reports, such as “arbitration,” “branch office,” “clearing firm,” “judgment,” and 

“lien.” The defined terms also cover forms, including Form BD, Form BDW, Form U4, Form 

U5 and Form U6, providing explanations of each. The BrokerCheck glossary explains some, but 

not all, industry examinations, including supervisory examinations. Similarly, the glossary on 

IAPD covers terms commonly used in the advisory industry, such as “client,” “discretionary 

authority,” “performance-based fee,” and “wrap fee program.” The defined terms also cover 

terms used on the forms, such as “advisory affiliate,” “investment-related,” and “management 

persons.” Terms used by regulators, such as “notice filing,” and legal terms appear in the 

glossary as well. 

The Staff recommends that both Web sites include additional glossary definitions and 

explanatory material, written in a succinct and accessible manner. Investor testing or other 

means of soliciting investor input could help determine the terms that investors find confusing 

and would like to have explained and defined. 

B. Intermediate-Term Recommendation – Continued Analysis of BrokerCheck and 

IAPD 

The Staff also recommends that, subsequent to the eighteen-month implementation 

period, Commission staff and FINRA continue to analyze, including through investor testing, the 

feasibility and advisability of expanding BrokerCheck to include information currently available 

in CRD, as well as the method and format of publishing that information; and that Commission 

staff continue to evaluate expanding IAPD content and the method and format of publishing that 

content, including through investor testing. 
 

43

 

Access to information filed on CRD and IARD can help investors make better decisions 

about their selection or evaluation of broker-dealers and investment advisers, and the Staff 

believes that such information should be disclosed to the public. The Commission has long 

expressed the view that registration information about financial services providers is key to 

making sound investment decisions.112 As described above, IAPD and BrokerCheck are systems 

that provide investors important data about the financial services providers on whom they will 

rely in helping to meet their investment goals. While the Commission has stated that 

BrokerCheck is “a valuable tool for an investor to use to get information about a firm or a 

registered person with whom the investor is considering doing business,” the Commission 

nonetheless has “urge[d] investors to check with each state where the firm has done business or 

where the sales person has been registered to obtain a complete picture of his or her disciplinary 

history.”113 Moreover, the Commission previously has encouraged FINRA to consider 

increasing the amount of information available on BrokerCheck.114

112 See, e.g., Investment Advisers Act Release No. 3060 (July 28, 2010) [75 FR 49234 n.5 (Aug. 12, 

2010)] (adopting amendments to Form ADV) (stating that “the disclosure clients and prospective 

clients receive is critical to their ability to make an informed decision about whether to engage an 

adviser and, having engaged the adviser, to manage the relationship.”). 

113 Exchange Act Release No. 55127 (Jan. 18, 2007) [72 FR 3455, 3461 (Jan. 25, 2007)]. 

114 Exchange Act Release No. 62476 (July 8, 2010) [75 FR 41254 (July 15, 2010)] (SR-FINRA-2010-

012) (“The Commission urges FINRA to consider expanding the information as suggested by the 

commenters. This information is available from the individual states; however, it would be more 

accessible through BrokerCheck. The Commission urges the public to utilize all sources of 

information particularly, the databases of the state regulators, as well as legal search engines and 

records searches, in conducting a thorough search of any associated person’s activities.”). In 

addition, information about other actions that are not disclosed on BrokerCheck may be available 

through other public sources, such as online search engines, regulators’ Web sites, and fee-based 

services such as Lexis or Westlaw. Id. 
 

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As discussed, regulators currently collect more information on registration forms than is 

made publicly available on BrokerCheck. For example, BrokerCheck excludes information 

reported on Form U5 concerning the reason for a registered representative’s termination and any 

comments from the former registered representative regarding that termination reported on Form 

U5. Also, as discussed, FINRA excludes from BrokerCheck, generally, information on Form U4 

for registered representatives who have terminated registration more than ten years ago.115 

Historical filings are another type of content that may be of interest to investors. BrokerCheck 

and IAPD provide only the most recent filings by broker-dealers, investment advisers, and their 

associated persons; they do not provide access to previous filings. Expanding BrokerCheck and 

IAPD to include registration data from previously filed registration forms, or amendments to 

them, would permit investors to review a firm’s filing history and the changes the firm has 

undergone over time. Investor input could help determine whether investors would find any of 

this additional information useful.116

Similarly, investor input could help determine whether to revise formatting on the 

BrokerCheck or IAPD Web sites. For example, focus group testing may be an effective way to 

evaluate the usefulness of summary disclosure compared to full presentation of original 

documents, such as Form ADV. Such testing could also help determine whether investors would 

prefer to have the option to view a summary page on IAPD for advisory firms, similar to the 

summary data available on BrokerCheck and for investment adviser representatives on IAPD. 

115 See FINRA Rule 8312(b)(1). 

116 The Staff is unaware of any formal information-gathering regarding investors’ views of BrokerCheck 

or IAPD. 
 

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Another possible modification to the BrokerCheck and IAPD Web sites is to hyperlink CRD 

numbers and SEC file numbers to information relating to owners, officers and affiliates 

associated with those numbers. The addition of these hyperlinks could make other business 

activities of broker-dealer and investment advisers, and their owners and officers, more 

transparent to investors. In addition, providing hyperlinks to content now available in 

BrokerCheck, which investors may obtain by clicking on the separate filings, could also provide 

investors with helpful information. 

VIII. Conclusion

Individual investors need useful tools to help them make important decisions about hiring 

and retaining broker-dealers and investment advisers. While BrokerCheck and IAPD currently 

are very helpful to investors, the recommendations in this study are intended to make these 

systems more accessible and useful to investors. This study responds to the requirement of 

Section 919B of the Act, which mandates that the Commission analyze the advantages and 

disadvantages of further centralizing access to registration information contained in CRD and 

IARD, identify data pertinent to investors and the method and format for displaying and 

publishing the data to enhance their accessibility by, and utility to, investors. It also responds to 

the requirement to provide recommendations to improve investor access to registration 

information and to identify additional information that could be made publicly available.