FINRA Regulatory Notice 25-09: Streamlining Disclosure Delivery Through FinPro Gateway

FINRA has released Regulatory Notice 25-09 announcing new system enhancements that give member firms an optional, modernized way to meet several key disclosure requirements for associated persons. As part of the FINRA Forward modernization initiative, these updates are designed to reduce manual, paper-based processes and improve operational efficiency.

Regulatory Background

Firms must provide associated persons with required information related to Forms U4 and U5 and the Predispute Arbitration Disclosure. These obligations stem from:

• FINRA Rule 1010(c) – Form U4 filing requirements
• Article V, Section 3 of FINRA By-Laws – Form U5 termination notification
• FINRA Rule 2263 – Arbitration disclosure requirements

Traditional delivery methods have often relied on certified mail or other manual processes.

Key Enhancements

• Electronic Delivery via FinPro Gateway: Firms can now deliver initial and amended Forms U4/U5 and the required Predispute Arbitration Disclosure directly through FinPro Gateway.
• Electronic Acknowledgment: The platform enables firms to capture written (electronic) acknowledgment from associated persons, fully satisfying Rule 1010(c)(2).
• Improved Efficiency: Centralized, documented, and cost-effective delivery—reducing administrative burdens and enhancing compliance workflows.

What Member Firms Should Do Next

• Ensure FinPro Enrollment: Confirm all associated persons have active FinPro accounts with valid email addresses.
• Provide Notice: Inform associated persons in writing that the firm intends to use FinPro Gateway for electronic disclosure delivery.
• Obtain Acknowledgment: Secure acknowledgment from associated persons confirming they understand and agree to receive these disclosures electronically via FinPro.