The Arizona securities dealer registration is built around Form BD, the Uniform Application for Broker-Dealer Registration, which any firm that buys or sells securities for others in Arizona must file with the Arizona Corporation Commission (ACC) Securities Division under A.R.S. § 44-1941. The form tells the state who runs your firm, who owns it, what you sell, and whether anyone tied to the business has a troubled legal or financial past.
Get a single answer wrong, and your filing can sit in limbo for weeks, or worse, draw a denial that follows you to every other state. Arizona ties three different paths to the same Form BD: FINRA-member dealers, non-FINRA dealers, and issuer-dealers, each with its own fee, filing channel, and extra paperwork. The most common version in use is SEC Form BD (SEC 1490), and you should confirm the revision date printed in the form’s footer before you start so you know you have the current copy.
Across the country, broker-dealer applications routinely take 45 days or more for the SEC to act on, and a single incomplete disclosure question is one of the top reasons a filing gets kicked back. This guide walks you through every item, box, and schedule so your filing clears the first time.
- 📋 How to complete all 13 items of Form BD, line by line, in plain English.
- 🏦 Which of the three Arizona paths (FINRA, non-FINRA, issuer-dealer) applies to you and what each one costs.
- 🧾 The exact documents, fees, and signatures you must gather before you open the form.
- ⚠️ The field-level mistakes that trigger holds, deficiency letters, and outright denials.
- ✅ Where and how to file, what happens after, and answers to the questions filers ask most.
What Form BD Is and Who Must File It
Form BD is the single uniform application a firm uses to register as a securities dealer with the SEC, with self-regulatory organizations like FINRA, and with each state where it does business, including Arizona. In Arizona, the form is the heart of dealer registration under A.R.S. § 44-1941, and the Securities Division of the Arizona Corporation Commission is the agency that receives and reviews it. The statute requires registration before a firm transacts business as a dealer, so filing late or skipping it is not a paperwork slip, it is unlawful activity.
A “dealer” in Arizona is, broadly, any person or firm in the business of buying or selling securities for the account of others or for its own account. If your firm does that and touches Arizona investors, you must register unless an exemption applies. The penalty for acting as an unregistered dealer can include administrative orders, restitution, and civil penalties, so the registration is the gate you pass through before you take a single order.
Arizona splits dealers into three groups, and the group you fall into decides your fee, your filing channel, and your extra documents. FINRA-member dealers file Form BD through the FINRA WebCRD system and pay a $300 fee. Non-FINRA dealers file a manually signed, notarized Form BD directly with the Division and also pay $300. Issuer-dealers, meaning firms that sell only their own securities, file directly with the Division, pay $100 under A.R.S. § 44-1861(B), and must attach formation documents, a prospectus, and proof of a qualified principal. All three groups must process under A.A.C. R14-4-147, the rule that governs how the Division acts on applications.
Before You Start: Documents and Information You Need
Gather everything below before you open Form BD, because the form asks for precise data the state cross-checks, and a missing item stalls the whole filing. The Division reviews your application under A.R.S. § 44-1942 and can request more information at any point, which adds weeks if you are scrambling.
- Firm’s exact legal name and any DBA names. The name must match your formation documents, because a mismatch makes the Division question who is really applying.
- IRS Employer Identification Number (EIN). The form uses this as your tax ID, and a wrong digit can tie your filing to another entity.
- CRD number, if you already have one. FINRA-member firms need this to file through WebCRD, and without it the system cannot route your Arizona request.
- Principal place of business address. A P.O. Box alone will not do, because the state needs a physical location for service and exams.
- Names, titles, and ownership percentages of every direct owner and executive officer. These feed Schedule A, and leaving one out understates who controls the firm.
- Names and ownership chains of indirect owners holding 25% or more. These feed Schedule B, and missing an upstream parent triggers a deficiency.
- Full disclosure history for the firm and its control persons. Any past criminal, regulatory, civil, or financial events drive Item 11 and the Disclosure Reporting Pages.
- Audited financial statements from an independent CPA. A.R.S. § 44-1941(A)(10) requires a balance sheet and related statements as of a recent date, and without them the Division cannot judge your solvency.
- The correct fee. FINRA and non-FINRA dealers owe $300 under A.R.S. § 44-1861(A); issuer-dealers owe $100, and the wrong amount delays acceptance.
- A notary, for paper filers. Non-FINRA and issuer-dealer Form BD pages must be manually signed and notarized, and an unnotarized signature is rejected on sight.
Issuer-dealers must gather more: articles of incorporation and bylaws (or the partnership or LLC operating agreement), a CPA consent letter, a prospectus for the offering, and the name and CRD or Social Security number of a designated principal who has passed the right exam. Confirm the live fee amounts on the ACC dealer registration page before you pay, since fee figures can change.
Where to Get the Form and How to Access It
You get the official Form BD in one of two places, depending on your path. FINRA-member firms access and file it electronically inside the FINRA Gateway / WebCRD system, where the form is built into the entitlement platform. Everyone else can download the blank SEC Form BD PDF and the ACC’s own form list on the Securities Forms page.
To file electronically, your firm first needs an entitlement account. The Super Account Administrator (SAA) sets up access, then your team can complete Form BD inside the system and request Arizona as a registration jurisdiction. WebCRD then routes the filing and your $300 fee to Arizona and bills the fee through the system, with checks payable to FINRA when sent to WebCRD.
Non-FINRA dealers and issuer-dealers skip WebCRD. They print Form BD, complete every required item, sign it in front of a notary, and mail it with their fee and attachments to the Securities Division. The official version to use is the current SEC Form BD; check the revision date in the footer of the SEC PDF so you are not filing an outdated copy. If you cannot find a field or are unsure which path fits, the Division answers questions at (602) 542-0326 or SEC-AOD@azcc.gov.
Step-by-Step: How to Fill Out Form BD Line by Line
Form BD has 13 numbered items plus Schedules A, B, C, D, and E and the Disclosure Reporting Pages. Items 1 through 13 must all be answered, and every required field must be complete before the filing is accepted. Work top to bottom and do not leave a box blank, because the system and the Division both treat blanks as deficiencies.
Item 1: Exact Name of Applicant
This item asks for the full legal name of the firm seeking registration, plus any name you do business under. Enter the name exactly as it appears on your articles of incorporation or other formation papers, in the format the form shows, and list each DBA in the space provided. For example, Cactus Capital Markets LLC would type its name in full and add d/b/a Cactus Trading if it uses that brand.
A common edge case is a recent name change that has not yet hit your formation records; if so, file under the official name on record and amend later, not the new name you plan to adopt. The most frequent mistake here is entering a marketing name instead of the registered legal name, which makes the Division unable to match you to your EIN and stalls the review. Many filers wrongly believe a DBA can stand in for the legal name; it cannot, because Arizona registers the legal entity, and the DBA is only an alias attached to it.
Item 2: Firm CRD Number and SEC File Number
This item asks for the identifying numbers the regulators already assigned to your firm, if any. Enter your CRD number and your SEC file number (the 8-prefixed number) in the boxes provided, and leave them blank only if you are brand new and have none yet. For example, an existing firm might enter CRD 123456 and SEC file number 8-67890.
The edge case is a first-time applicant with no numbers; the system issues a CRD number once you start the electronic filing, so you are not expected to invent one. The common mistake is transposing digits in the CRD number, which can attach your Arizona request to a different firm’s record and create a tangle that takes weeks to unwind. People often assume the SEC file number and CRD number are the same; they are not, and entering one in place of the other confuses the cross-check.
Item 3: Principal Place of Business and Mailing Address
This item asks where your firm actually operates and where it gets mail. Enter the full street address of your main office, then the mailing address if it differs, using complete city, state, and ZIP fields. For example, Cactus Capital Markets LLC enters 2400 E Camelback Rd, Suite 300, Phoenix, AZ 85016 as its principal office.
If your mailing address is a P.O. Box, you may use it in the mailing field, but the principal place of business must be a physical location, because the state needs somewhere to conduct exams and serve papers. The common mistake is listing only a P.O. Box as the principal office, which the Division rejects because a box is not a place of business. Filers often think a home address cannot be used; it can, if that is where the firm truly operates, since the rule is about a real location, not a commercial one.
Item 4: Contact Employee
This item asks for the person the regulators call when they have questions about the filing. Enter that employee’s full name, title, phone number, and email so the Division can reach a live human fast. For example, the firm might list Maria Lopez, Chief Compliance Officer, (602) 555-0148, mlopez@cactuscap.com.
The edge case is a tiny firm where the owner is the only employee; in that case, list the owner, since someone must be the contact. The common mistake is naming an outside attorney or consultant who is not an employee, which the form does not allow and which can bounce the filing. People assume the contact employee must be the CEO; it does not, and naming the compliance officer or operations lead is often the better choice because they know the filing detail.
Item 5: Type of Organization
This item asks how your firm is legally structured. Check the one box that fits: corporation, partnership, sole proprietorship, limited liability company, or other, and give the date and state of formation. For example, Cactus Capital Markets LLC checks limited liability company and enters Arizona with its formation date of 03/14/2024.
The edge case is a firm formed in one state but operating in Arizona; enter the true state of formation, not Arizona, because that is where your legal existence began. The common mistake is checking the wrong structure, which conflicts with your attached formation documents and forces the Division to ask which is correct. Many filers think an LLC is treated like a partnership on the form; it is its own box, and choosing the wrong one mismatches your owner schedules.
Item 6: Other Business Names and Successor Information
This item asks whether the firm uses other names or is taking over a prior registrant’s business. Answer yes or no, and if yes, identify the predecessor and complete the successor details and Schedule D where prompted. For example, a firm acquiring another dealer enters the predecessor’s name and CRD number to carry forward the registration.
The edge case is a merger where two firms combine; the surviving firm files as the successor and reports the change, since the registration does not simply transfer on its own. The common mistake is hiding a predecessor relationship to avoid extra questions, which the Division later discovers and treats as a material omission. People wrongly believe buying another firm automatically gives them its Arizona registration; it does not, because succession must be reported and approved.
Item 7: SRO and State Registrations
This item asks which self-regulatory organizations and which states your firm is registered or applying with. Check FINRA and any exchanges, then mark Arizona and every other jurisdiction where you seek registration, because this is how Arizona learns you want in. For example, a national firm checks FINRA and then marks AZ along with the other states on its expansion list.
The edge case is a firm registered with the SEC but not yet a FINRA member; non-FINRA dealers still file here but route the form to the Division, not WebCRD. The common mistake is forgetting to actually select Arizona, which means your fee posts but the state never receives a request, leaving you unregistered while you think you are done. Filers often assume SEC registration alone lets them operate in Arizona; it does not, because Arizona requires its own state-level registration on top of federal.
Item 8: Bank and Custody Arrangements
This item asks whether your firm holds customer funds or securities and how. Answer the custody questions honestly, because they tell the Division whether you trigger heightened net capital and safekeeping rules. For example, an introducing firm that clears through another broker checks that it does not hold customer assets.
The edge case is a firm that holds assets only briefly in transit; read the item carefully, since even temporary custody can change your answer. The common mistake is checking “no custody” to dodge net capital rules when the firm in fact touches customer money, which is a serious misrepresentation. People think using a clearing firm always means no custody; it usually does, but the answer depends on your exact arrangement, so confirm before you check the box.
Item 9: Control Relationships With Other Firms
This item asks whether your firm controls, is controlled by, or is under common control with any other broker-dealer or investment adviser. Answer yes or no, and list the related firms and their CRD numbers where prompted. For example, a dealer owned by the same parent as an affiliated adviser reports that adviser and its CRD number.
The edge case is a minority investment that falls short of control; if it is below the control threshold, you may answer no, but document your reasoning. The common mistake is omitting an affiliate to look independent, which surfaces during review and damages your credibility. Filers often think only majority ownership counts as control; the definition is broader and can include the power to direct management, so map your relationships carefully.
Item 10: Types of Business and Compensation
This item asks what your firm actually does and how it gets paid. Check every business activity that applies, from retail brokerage to underwriting to mutual fund sales, and the related compensation methods. For example, Cactus Capital Markets LLC checks broker or dealer retailing corporate equity securities and underwriter.
The edge case is a firm planning to add a line of business later; check only what you do now and amend when you expand, because the form must reflect current activity. The common mistake is checking too many boxes “just in case,” which invites questions about activities you are not ready to supervise. People assume listing more business types looks stronger; it does not, and overclaiming can trigger higher capital requirements and deeper scrutiny.
Item 11: Disclosure Questions
This item is the heart of the application and asks a long series of yes-or-no questions about the firm’s and its control affiliates’ criminal, regulatory, civil judicial, and financial history. Answer each subpart truthfully; a yes answer requires a matching Disclosure Reporting Page (DRP) with full details. For example, if a control person had a past regulatory fine, the firm answers yes to the relevant subpart and attaches a DRP explaining it.
The edge case is an old event from many years ago; you may still have to report it, since Form BD’s lookback differs from a simple ten-year rule, so read each question’s wording. The common mistake is answering no to avoid embarrassment, which becomes fraud once the background check finds the event and is one of the fastest ways to earn a denial. Many filers believe an expunged or dismissed matter never needs disclosure; often it still does, because the question may reach charges regardless of outcome, so when in doubt, disclose and explain on a DRP.
Item 12: Applicant’s Signature and Execution
This item is the signature block where an authorized person swears the filing is true. Sign and date it, and for non-FINRA and issuer-dealers, sign in front of a notary, because A.R.S. § 44-1941(A) requires a manually signed, notarized form. For example, Maria Lopez signs as an authorized officer and dates it 06/03/2026 with a complete month, day, and year.
The edge case is an electronic filing through WebCRD followed by a hard copy; FINRA still wants an originally signed, notarized paper Form BD mailed to its disclosure department. The common mistake is a missing or incomplete date, since the signature date must show a full month, day, and year or the form is treated as unexecuted. People think a mechanical or stamped signature is fine; the initial hard copy must bear an original signature, and reproductions are not accepted.
Item 13: Non-Resident Dealer Consent
This item handles dealers based outside the United States and their consent to service of process. Complete it only if it applies, and pair it with the uniform consent to service of process where the state requires it. For example, a foreign-based applicant signs the consent so Arizona can serve legal papers through the Commission.
The edge case is a U.S. firm with only a foreign parent; the firm itself may be domestic, so read the item before completing it. The common mistake is skipping the consent to service of process, which leaves the state unable to serve you and blocks effective registration. Filers often assume an out-of-state but in-country dealer must complete this; it is aimed at non-U.S. applicants, while in-state service is handled through other consents.
Schedule A: Direct Owners and Executive Officers
Schedule A asks for every direct owner and executive officer, completed on an initial application. List each CEO, CFO, COO, chief legal officer, chief compliance officer, director, and any 5%-or-more direct owner, with the DE/FE/I code, title or status, ownership code, and control-person answer. For example, Maria Lopez appears as I (individual), title Chief Compliance Officer, ownership code NA if she owns less than 5%, control person Yes.
The edge case is an owner who sits just under 5%; ownership code NA covers less than 5%, so read the bands carefully. The common mistake is leaving off the chief compliance officer, who is required and must be exactly one person, which makes the schedule incomplete on its face. People think only owners go here; executive officers belong on Schedule A too, even if they own nothing, because the state tracks control as well as equity.
Schedule B: Indirect Owners
Schedule B asks for indirect owners, meaning the people and entities above your direct owners who hold 25% or more as you climb the ownership chain. Complete it after Schedule A on an initial application, listing each upstream owner with the DE/FE/I code, status, ownership code, and control answer, continuing up until you reach the individuals at the top. For example, if a holding company owns the dealer, the holding company’s 25%-plus owners are listed here.
The edge case is a long chain of entities; you must keep climbing and list every 25% owner at each level, not just the first parent. The common mistake is stopping at the immediate parent, which hides the real people in control and produces a deficiency once the Division asks who owns the parent. Filers often assume only the firm’s direct shareholders matter; Schedule B exists precisely to expose the indirect owners standing behind them.
Schedules C, D, and E
Schedule C is the amendment schedule used to change owner information on Schedules A and B after the initial filing, not for the first application. Schedule D captures other business names, successor details, and certain office and bank information the items point to. Schedule E covers branch office data where the form requires it.
The edge case is a post-filing ownership change; use Schedule C to add, delete, or amend, rather than re-submitting the original schedules. The common mistake is using Schedule A or B to make later changes, which the system rejects because amendments belong on Schedule C. People think these schedules are optional extras; they are required whenever the matching item triggers them, and skipping a triggered schedule blocks acceptance.
Three Filled-Out Examples Using Real Scenarios
Below are three named filers walking the full path, one per Arizona dealer type. Each table shows the key entries that filer makes.
Scenario 1: National FINRA-Member Dealer Adding Arizona — Summit Brokerage Partners Inc., an existing FINRA member, expands into Arizona through WebCRD.
| Form Section | What Summit Enters |
|---|---|
| Item 1: Name | Summit Brokerage Partners Inc. |
| Item 2: CRD / SEC number | CRD 234567, SEC file 8-55512 |
| Item 5: Organization type | Corporation, formed in Delaware |
| Item 7: SRO / states | FINRA checked, AZ selected as new jurisdiction |
| Item 10: Business types | Retail equity brokerage, mutual fund sales |
| Item 11: Disclosures | No to all, no DRPs needed |
| Schedule A | CEO, CFO, and CCO listed with control = Yes |
| Filing channel | WebCRD, $300 fee routed to Arizona |
| Extra document | Audited financials filed directly with the Division |
Scenario 2: Small Non-FINRA Dealer — Desert Bond Securities LLC registers directly with the Division on paper.
| Form Section | What Desert Bond Enters |
|---|---|
| Item 1: Name | Desert Bond Securities LLC |
| Item 2: CRD / SEC number | Left blank as a first-time, non-FINRA applicant |
| Item 5: Organization type | Limited liability company, formed in Arizona |
| Item 7: SRO / states | No SRO checked, AZ marked |
| Item 10: Business types | Dealing in municipal and corporate bonds |
| Item 11: Disclosures | No to all subparts |
| Item 12: Signature | Manually signed and notarized |
| Filing channel | Mailed to Securities Division, $300 check to the ACC |
| Extra document | Independent CPA audit report attached |
Scenario 3: Startup Issuer-Dealer in a Reg A Offering — Sonoran Solar Inc. sells only its own shares and registers as an issuer-dealer.
| Form Section | What Sonoran Solar Enters |
|---|---|
| Item 1: Name | Sonoran Solar Inc. |
| Item 5: Organization type | Corporation, formed in Arizona |
| Item 7: SRO / states | No SRO, AZ only |
| Item 10: Business types | Selling securities of which it is the issuer |
| Item 11: Disclosures | No to all subparts |
| Item 12: Signature | Manually signed and notarized |
| Designated principal | David Nguyen, with CRD number and passed exam, on Form U-4 |
| Filing channel | Mailed to Securities Division, $100 fee to the ACC |
| Extra documents | Articles, bylaws, CPA consent, prospectus, audit report |
How to File the Completed Form
Your filing channel depends on your dealer type, and each channel has its own address, fee, and proof to keep. Confirm current fees on the ACC dealer page before you send money.
FINRA-member dealers — file electronically. Submit Form BD through FINRA WebCRD and request Arizona as a jurisdiction. The $300 fee is paid through WebCRD with checks payable to FINRA, and the system processes the fee for you. FINRA also wants an originally signed, notarized hard copy mailed to its Regulatory Review and Disclosure Department at 9509 Key West Avenue, Rockville, MD 20850. Keep your WebCRD filing confirmation and the dated funding record as proof. Electronic processing is the fastest route, though the Division’s own review can still take time.
Non-FINRA dealers — file by mail. Mail the manually signed, notarized Form BD with a $300 check payable to the Arizona Corporation Commission, plus your audited financials, to the Securities Division, Arizona Corporation Commission, 1300 West Washington, Third Floor, Phoenix, AZ 85007. Send it certified with return receipt, and keep the stamped copy and mailing receipt as proof of the filing date.
Issuer-dealers — file by mail. Mail the notarized Form BD with a $100 check payable to the Arizona Corporation Commission, along with your formation documents, CPA consent, prospectus, audited financials, and Form U-4 for the designated principal, to the same Phoenix address. Keep copies of every attachment and your certified-mail receipt. For any channel, the Division reviews under A.R.S. § 44-1942 and may request more information, so build in time for follow-up.
What Happens After You File
Once your filing lands, the Division reviews everything you submitted under A.R.S. § 44-1942 and may ask for more information before it acts. For FINRA firms, the SEC and FINRA approvals in your home state also matter, since Arizona looks for approval by the SRO and by the state of your principal place of business. Plan for a multi-week wait, and remember the SEC itself often takes around 45 days to act on a broker-dealer application.
If the Division finds gaps, you get a deficiency request, and the clock effectively pauses until you respond. A clean filing moves toward effective registration, after which your firm may lawfully transact dealer business in Arizona. A flawed one can draw a denial proceeding, which is far harder to undo than a quick correction.
Registration is not a one-and-done event. To keep it, you must file all Form BD amendments as changes occur or within 90 days under A.R.S. § 44-1948(A), file annual audited financials when you file them with the SEC, and pay the annual fee. FINRA and non-FINRA dealers pay $300 by the last working day of December; issuer-dealers pay $100 before their registration anniversary, since an issuer-dealer’s registration expires one year from its effective date under A.R.S. § 44-1947(B).
Mistakes to Avoid When Filling Out the Form
- Filing under a marketing name instead of the legal name in Item 1, which breaks the match to your EIN and stalls review.
- Transposing digits in your CRD number in Item 2, which can attach your request to another firm’s record.
- Listing only a P.O. Box as your principal place of business in Item 3, which the Division rejects outright.
- Naming an outside consultant as the contact employee in Item 4, which the form does not allow.
- Checking the wrong organization type in Item 5, which conflicts with your formation documents.
- Forgetting to actually select Arizona in Item 7, which leaves you unregistered even after paying.
- Misstating custody in Item 8, which is a serious misrepresentation about customer assets.
- Answering “no” on an Item 11 disclosure to hide a past event, which the background check finds and treats as fraud.
- Leaving the signature date in Item 12 incomplete, which makes the form unexecuted and unacceptable.
- Skipping notarization on a paper Form BD, which gets the filing bounced immediately.
- Stopping Schedule B at the first parent instead of climbing to the top owners, which produces a deficiency.
- Sending the wrong fee, $300 instead of $100 or the reverse, which delays acceptance.
Do’s and Don’ts
Do: – Do confirm the Form BD revision date and current fees before filing, because outdated forms and wrong fees get bounced. – Do gather audited financials early, since A.R.S. § 44-1941(A)(10) requires them and they take time to prepare. – Do disclose every reportable event on Item 11 and its DRPs, because honesty beats the denial that follows a hidden record. – Do file by certified mail with return receipt, so you can prove your filing date if a dispute arises. – Do answer all 13 items completely, since any required blank stops acceptance. – Do calendar your renewal and amendment deadlines, because late filings under A.R.S. § 44-1948(A) put your registration at risk.
Don’t: – Don’t guess on disclosure questions, because a wrong “no” can become a fraud finding. – Don’t use a P.O. Box as your principal office, since the state needs a real location. – Don’t sign without a notary if you file on paper, because unnotarized forms are rejected. – Don’t overstate your business types in Item 10, since overclaiming triggers higher capital and scrutiny. – Don’t omit affiliates in Item 9, because hidden control relationships surface and hurt your credibility. – Don’t assume SEC registration alone covers Arizona, since the state requires its own registration.
Pros and Cons of Filing on Your Own vs. With Help
| Filing on Your Own | Filing With a Compliance Pro or Attorney |
|---|---|
| Saves professional fees, which matters for a lean startup. | Costs money, but often less than fixing a denied filing. |
| Builds in-house knowledge of your own filing. | Brings deep knowledge of Item 11 and DRP traps. |
| Works for simple firms with clean histories. | Best when control persons have disclosure events. |
| Full control over timing and content. | Speeds review by submitting it right the first time. |
| Direct contact with the Division on questions. | Manages WebCRD entitlement and multi-state filings. |
| Risk of missed schedules and blank fields. | Reduces the risk of holds, deficiencies, and denials. |
FAQs
Do I have to register before I do any dealer business in Arizona?
Yes. Arizona requires dealer registration under A.R.S. § 44-1941 before you transact business, and acting first can bring administrative orders, restitution, and penalties.
Do FINRA-member and non-FINRA dealers pay the same Arizona fee?
Yes. Both pay a $300 registration fee under A.R.S. § 44-1861(A), though FINRA firms pay through WebCRD and non-FINRA firms pay the Commission directly.
Do issuer-dealers pay a lower fee?
Yes. Issuer-dealers pay $100 under A.R.S. § 44-1861(B), and their registration expires one year from the effective date, so they renew annually for $100.
Do I file Form BD online or on paper?
Yes, it depends on your type. FINRA members file through WebCRD, while non-FINRA dealers and issuer-dealers file a notarized paper Form BD with the Division.
Do I write my legal name or my DBA in Item 1?
Yes, use the legal name. Enter the firm’s exact registered legal name in Item 1 and list any DBA separately, because Arizona registers the legal entity.
Do I need a CRD number in Item 2 if I am brand new?
No. First-time non-FINRA applicants can leave it blank, and WebCRD issues a CRD number to electronic filers when the filing begins.
Do I list executive officers on Schedule A even if they own no stock?
Yes. Schedule A captures executive officers and directors regardless of ownership, and the chief compliance officer must be listed and must be one person.
Do I have to climb the whole ownership chain on Schedule B?
Yes. List every indirect owner of 25% or more at each level up the chain, because stopping at the first parent creates a deficiency.
Do I report an old or dismissed legal matter on Item 11?
Yes, often you must. Many Item 11 questions reach charges regardless of outcome, so disclose and explain on a DRP when unsure rather than risk a fraud finding.
Do non-FINRA dealers need their Form BD notarized?
Yes. A.R.S. § 44-1941(A) requires a manually signed, notarized Form BD for non-FINRA and issuer-dealers, and an unnotarized form is rejected.
Do I need audited financial statements to register?
Yes. A.R.S. § 44-1941(A)(10) requires audited financials from an independent CPA, unless you are not yet required to provide them under SEC rules.
Do I have to keep filing after I am registered?
Yes. You must file amendments within 90 days, file annual audited financials, and pay the annual fee under A.R.S. § 44-1948(A) to stay registered.
Do I select Arizona somewhere on the form, or is filing enough?
Yes, you must select it. In Item 7 you mark Arizona as a jurisdiction, and forgetting to do so leaves you unregistered even after the fee posts.
Do I have to be a FINRA member to register in Arizona?
No. Arizona registers FINRA members, non-FINRA dealers, and issuer-dealers, each through its own path, so FINRA membership is not required for every applicant.
Related reading
- How to Fill Out SEC Form BD (w/Examples) + FAQs
- How to Fill Out Massachusetts Securities Broker-Dealer Registration + FAQs
- How to Fill Out Washington DFI Securities Broker-Dealer Registration (Form BD) + FAQs
- How to Fill Out Georgia Securities Dealer Registration (GA) + FAQs
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