How to Fill Out Washington DFI Securities Broker-Dealer Registration (Form BD) + FAQs

Form BD is the Uniform Application for Broker-Dealer Registration, and it is the form your firm files to register as a securities broker-dealer in Washington State with the Department of Financial Institutions (DFI) Securities Division. Under RCW 21.20.040, no firm may transact business as a broker-dealer in Washington unless it is registered, and Form BD is the document that carries that request to the state.

The form does more than introduce your firm. It tells the DFI director who owns the firm, who runs it, what kind of securities business it does, and whether anyone in control has a disciplinary or criminal history. A wrong answer on the disclosure items or a missing owner on Schedule A can stall your application for weeks or trigger a denial, so accuracy is not optional. The current SEC Form BD shows an OMB expiration of April 30, 2026 in its upper corner, so confirm you are using that version before you start, since the Central Registration Depository (CRD) rejects outdated paper copies.

Here is what you will learn in this guide:

  • 📋 What Form BD is, who must file it in Washington, and the difference between the FINRA and non-FINRA filing paths under WAC 460-20C-030
  • 🗂️ Every document, ID number, and fee you need to gather before you open the form
  • ✍️ A line-by-line walkthrough of each Form BD item, schedule, and disclosure page with sample entries
  • 👥 Three full filing scenarios that follow real firms through the form from start to finish
  • ⚠️ The mistakes that get applications held or denied, plus a do’s and don’ts list and answers to common field-level questions

What Form BD Is and Who Must File It

Form BD is a single uniform application that lets a firm register at the same time with the SEC, the self-regulatory organizations, and any of the states it names in Item 2. In Washington, the state piece of that filing is governed by the Securities Act of Washington, chapter 21.20 RCW, and the rules in chapter 460-20C of the Washington Administrative Code. The agency that receives and reviews the Washington portion is the DFI Securities Division, and its director has the authority to approve, deny, or condition your registration.

You must file Form BD with Washington if your firm meets the definition of a broker-dealer and will transact business with people in the state. A broker-dealer is any person in the business of effecting securities transactions for the account of others or for its own account. The deadline is simple but strict: you must be registered before you do any broker-dealer business in Washington, not after, because RCW 21.20.040 bars unregistered activity outright.

The penalty for getting this wrong is serious. Transacting business without registration can lead to a cease-and-desist order, fines, and rescission rights for customers, and a false statement on the form itself can constitute a criminal violation, as the warning on Page 1 of Form BD plainly states. The statute, the agency, the deadline, and the penalty all connect: the agency enforces the statute, the deadline tells you when the statute applies, and the penalty is what follows if you ignore either.

There are two filing paths, and which one you use changes everything about how you submit the form. If your firm is a FINRA member, you file electronically through CRD. If your firm is not a FINRA member, you file paper directly with the DFI director and must attach extra financial proof, as set out in WAC 460-20C-030.

Filing Path What It Means for You
FINRA member File Form BD, fees, and salesperson U4s through CRD; Washington pulls the filing electronically
Non-FINRA member File paper Form BD directly with the director, plus a cover letter, balance sheet, net capital computation, and exam proof

Before You Start: Documents and Information You Need

Gather everything below before you open the form, because Form BD asks for precise legal and financial detail that you cannot guess at. A missing item does not just slow you down; it can cause CRD to reject the filing or cause the director to issue a deficiency letter that pauses your application clock.

  • Your firm’s exact full legal name as it appears in your formation documents, needed for Item 1A, because a mismatch with state corporate records triggers a hold.
  • Your IRS Employer Identification Number (EIN), needed for Item 1B, since the agency cross-checks it and a wrong number stalls processing.
  • Your firm CRD number if you already have one, needed on every page header, because filing under the wrong number can attach your data to another firm.
  • Your principal business street address (no P.O. Box allowed in Item 1E), because the form rejects a P.O. Box in the main address field.
  • The state and date of formation and the month your fiscal year ends, needed for Item 3, because the director verifies your legal status.
  • A complete list of direct owners and executive officers with ownership percentages, needed for Schedule A, because a missing 5% owner is a material omission.
  • A complete list of indirect owners holding 25% or more up the chain, needed for Schedule B, because hidden ownership is a common cause of denial.
  • Full details of any disciplinary, criminal, regulatory, civil, or financial event for the firm or any control affiliate, needed for Item 11 and the Disclosure Reporting Pages, because an undisclosed event can be treated as fraud.
  • Proof of passed qualifying exams for your designated principals under WAC 460-20C-040, required for non-FINRA filers and verified before approval.
  • A current balance sheet dated within 120 days plus a net capital and aggregate indebtedness computation, required for non-FINRA filers under WAC 460-20C-110, because thin capital can be cured only with a surety bond.

Where to Get the Form and How to Access It

You can download the official paper version of Form BD from the SEC website, and you should always pull the current version because CRD will not accept an outdated form. FINRA members do not actually fill out the paper PDF for routine work; instead they complete the electronic version inside the CRD system, now accessed through FINRA Gateway. The paper PDF is still useful as a worksheet so your team can draft answers offline before keying them into the system.

First-time CRD applicants must submit a full paper Form BD with an original, manually signed and notarized Execution Page (Page 1) the first time they file with CRD, even though later amendments are electronic. To use CRD at all, your firm first sets up a CRD account and funds a Flex-Funding or Daily account from which Washington’s fee is drawn. The CRD mailing address for paper questions and correspondence is NASAA/FINRA Central Registration Depository, P.O. Box 9495, Gaithersburg, MD 20898-9495.

Non-FINRA firms skip CRD for the state filing and send the paper Form BD straight to the DFI Securities Division. You can reach the division through the Washington DFI Securities Division page, which lists the current mailing address and contact staff. Either way, keep a stamped or electronic copy of everything you submit, because that copy is your proof of filing if a question about timing ever arises.

Step-by-Step: How to Fill Out Form BD Line by Line

The body of Form BD runs from the Execution Page through Items 1 to 13 and then the Schedules and Disclosure Reporting Pages. Work through it in order, because later items and schedules build on the legal status and ownership facts you set early in the form. Below, each major field gets its own walkthrough.

Top of Every Page: Date, SEC File No., and Firm CRD No.

In plain English, the header on each page asks who is filing and ties every page to one firm. You answer it by entering the filing Date, your SEC File No. (the number after the “8-” prefix), and your Firm CRD No. in the boxes at the top of each page. For example, Cascade Securities LLC writes 05/30/2026 in the date box and Firm CRD No.: 123456 once the number is assigned.

A common nuance is the brand-new firm that has no CRD number yet; in that case you leave the field blank on the very first paper filing, and CRD assigns the number after you submit. The most common mistake here is copying another entity’s CRD number onto your pages, and the direct consequence is that your filing attaches to the wrong firm’s record and must be unwound by FINRA staff. Many filers wrongly believe the header is decorative and skip it, but the agency uses it to keep multi-page filings from getting separated, so fill it in on every page.

Application or Amendment Checkbox

This field asks whether you are registering for the first time or changing an existing registration. You answer by checking the APPLICATION box for an initial Washington registration, or the AMENDMENT box if your firm is already registered and you are updating information. For example, a firm registering in Washington for the first time checks APPLICATION, while a firm adding a new executive officer later checks AMENDMENT.

The nuance to watch is an out-of-state firm already registered with the SEC and other states that now wants to add Washington; that firm files an amendment to add Washington in Item 2 rather than a brand-new application. The common mistake is checking AMENDMENT on a true first filing, and the consequence is that CRD cannot find a prior record to attach to and rejects the submission. People often think any change requires a fresh application, but most updates after your first filing are amendments, which is faster and avoids a duplicate fee.

Item 1: Firm Name, Address, and Contact Employee

Item 1 asks for your firm’s exact identity and how the agency can reach you. You complete Item 1A with the full legal name, Item 1B with the EIN, Item 1C with any “doing business as” name, Item 1E with the physical street address (no P.O. Box), Item 1F with a mailing address if different, Item 1G with the phone number, and Item 1H with the contact employee who receives compliance mail. For example, Cascade Securities LLC enters Cascade Securities LLC in 1A, 91-1234567 in 1B, and names Dana Rivera, Chief Compliance Officer in 1H.

A frequent edge case is a firm that operates under a trade name; that “other” name goes in Item 1C and is also listed on Schedule D, Page 1, Section I with the states where it is used. The most common mistake is putting a P.O. Box in Item 1E, and the direct consequence is that the form is rejected because the main address field bars P.O. Boxes outright. Many filers assume the contact employee can be any junior staffer, but this person must be authorized to receive and route all compliance communications, so naming someone without that authority creates a real supervisory gap.

Item 2: Registration Authorities and Jurisdictions (Check Washington)

Item 2 asks which regulators and states you are registering with, and this is where Washington gets selected. You check the SEC box and answer Items 2A through 2D if you register with the SEC, check the FINRA box under SRO if you are a FINRA member, and then check the Washington box in the jurisdiction list. For example, a national firm checks the SEC box, answers Yes to Item 2A, checks FINRA, and checks Washington along with any other states it serves.

The nuance here involves government securities firms: a firm that also deals in government securities answers Yes to Item 2B, while a firm dealing only in government securities answers Yes to Item 2C and must not also answer 2A or 2B. The most common mistake is forgetting to check the Washington box itself, and the consequence is that your firm never actually requests Washington registration even though it paid attention to everything else. Filers often think checking the SEC box automatically covers the states, but each state must be checked individually, and Washington will not see your filing unless its box is marked.

Item 3 and Schedules A & B: Legal Status and Ownership

Item 3 asks for your firm’s legal form, where and when it was created, and its fiscal year end. You check the box for Corporation, Partnership, Sole Proprietorship, Limited Liability Company, or Other in Item 3A, enter the fiscal year-end month, and complete Item 3C with the state of formation, country, and formation date. For example, Cascade Securities LLC checks Limited Liability Company, lists Washington as state of formation, and enters 03/01/2025 as the formation date.

Because Item 3 is tied to ownership, you must also complete Schedule A (direct owners and executive officers) and, if anyone is reported there as an entity, Schedule B (indirect owners) with every initial application. Schedule A captures each CEO, CFO, COO, CLO, CCO, director, and every person owning 5% or more of a voting class, using the ownership codes (A for 5% to under 10%, up through E for 75% or more). The most common mistake is omitting a 5% owner or an officer from Schedule A, and the direct consequence is a material omission that can void the registration; a common misconception is that only majority owners must appear, when in fact the 5% direct and 25% indirect thresholds control.

Items 5 Through 9: Successions, Custody, Referrals, and Arrangements

These items ask about your firm’s structure and relationships. You answer Item 5 Yes or No on whether you are succeeding to another registered broker-dealer, Item 6 on whether you hold customer funds or securities or clear for others, Item 7 on whether you refer customers to another broker-dealer, and Items 8 and 9 on clearing, financing, and control arrangements, each detailed on Schedule D, Page 1, Section IV. For example, an introducing firm answers No to Item 6 and Yes to Item 7, then names its clearing firm on Schedule D.

A key nuance is succession under Item 5: if you are taking over a registered firm’s business, you must contact CRD before submitting and follow SEC Rule 15b1-3 for the transfer. The common mistake is answering Yes to Item 5 without first coordinating with CRD, and the consequence is a tangled record that delays both your filing and the predecessor’s withdrawal. Filers often misread Item 6 as covering only firms that physically hold cash, but providing clearing services for another broker also requires a Yes, so read the full prompt.

Item 11: Disclosure Questions and the Disclosure Reporting Pages (DRPs)

Item 11 is the heart of the form and asks, across parts A through K, whether the firm or any control affiliate has any criminal, regulatory, civil judicial, or financial event in its history. You answer each sub-question Yes or No, and for every Yes you must complete the matching Disclosure Reporting Page (DRP) describing the event in full. For example, if a control affiliate was once enjoined in an investment-related case, the firm answers Yes to Item 11H and files a DRP with the court, dates, and disposition.

The nuance most firms miss is the breadth of control affiliate: it reaches beyond the firm to officers, 25% owners, and anyone who controls or is controlled by the firm, so a director’s old disciplinary action can require a Yes. The most common and most damaging mistake is answering No to hide a reportable event, and the direct consequence is that the false answer itself becomes grounds for denial and possible criminal referral, far worse than the underlying event. A frequent misconception is that expunged, old, or out-of-state matters need not be reported, but Item 11 uses defined terms like found, charged, and order that often capture them, so disclose and explain rather than omit.

Item 12: Types of Business

Item 12 asks what kinds of securities business your firm does, listing categories A through Z with three-letter codes. You check every category that accounts for, or is expected to account for, at least 1% of your annual securities revenue, such as BDR for retailing corporate equities or MFR for mutual fund retailing. For example, a small introducing firm selling mutual funds and private placements checks MFR (Item 12H) and PLA (Item 12W).

The nuance is the 1% floor: you skip any line that will bring in less than 1% of revenue, which keeps the form honest about your real business mix. A common mistake is checking too many boxes “just in case,” and the consequence is that examiners may hold your firm to activities and net-capital expectations it never intended to take on. Many filers think Item 12 is a wish list of future plans, but it should reflect your actual or genuinely intended business, and you describe anything unusual under code OTH (Item 12Z) on Schedule D.

Item 13: Commodities and Other Non-Securities Business

Item 13 asks whether your firm trades commodity futures or options (Item 13A) and whether it does any other non-securities business (Item 13B). You answer each Yes or No, and if you answer Yes to 13B you briefly describe that business on Schedule D, Page 1, Section II. For example, a firm that also offers insurance products answers Yes to Item 13B and describes the insurance line on Schedule D.

The nuance is that non-securities business can raise conflict-of-interest and supervision questions, so the description should be clear and complete. The common mistake is leaving Item 13B blank when the firm clearly has an outside line of business, and the consequence is a deficiency letter asking you to explain the gap. Filers sometimes assume commodities and insurance are too far from securities to matter here, but the form specifically asks, and an inaccurate answer is still an inaccurate filing.

Page 1 Execution: Signature and Notarization

The Execution Page asks an authorized person to swear that the form is true and to consent to Washington’s jurisdiction for service of process. You complete it by entering the date, the applicant’s name, signing manually, printing the signer’s name and title, and having the signature notarized. For example, Dana Rivera, Chief Compliance Officer signs and prints her title, and a notary completes the block with a stamp and commission expiration.

The nuance is the surety-bond certification embedded in the execution language: by signing, you certify the firm complies with applicable state surety-bonding requirements, which matters most for thinly capitalized non-FINRA firms. The most common mistake is submitting a photocopied or unsigned Execution Page on a first filing, and the consequence is outright rejection because the first paper filing requires an original manual signature and notarization. People often assume an electronic signature suffices for the initial filing, but the rules require a wet-ink, notarized Page 1 the first time, with later amendments handled electronically.

Three Filled-Out Examples Using Real Scenarios

Below are three common ways firms register in Washington. Each table follows one named firm through the most important parts of Form BD.

Scenario 1 — New FINRA-member firm registering in Washington for the first time. Cascade Securities LLC, a brand-new Seattle introducing broker-dealer, files through CRD.

Form Section What Cascade Securities Enters
Application/Amendment Checks APPLICATION
Item 1A (Full legal name) Cascade Securities LLC
Item 1B (EIN) 91-1234567
Item 1E (Main address) 1200 Fifth Ave, Suite 400, Seattle, WA 98101
Item 2 (SRO / Jurisdiction) Checks SEC, Yes to 2A, FINRA, and Washington
Item 3A (Legal status) Limited Liability Company, formed in Washington, 03/01/2025
Schedule A Lists Dana Rivera (CCO) and two 50% members, ownership code D
Item 6 / Item 7 No to holding funds; Yes to introducing, clearing firm on Schedule D
Item 11 (Disclosure) No to all parts; no DRPs needed
Item 12 (Business types) Checks MFR and PLA
Execution Page Dana Rivera signs, notarized, original signature

Scenario 2 — Out-of-state FINRA firm adding Washington. Summit Brokerage Inc., already registered with the SEC and ten states, expands into Washington.

Form Section What Summit Brokerage Enters
Application/Amendment Checks AMENDMENT (firm already in CRD)
Item 1A Summit Brokerage Inc. (unchanged)
Item 2 (Jurisdiction) Adds a check in the Washington box
Item 3A Corporation, formed in Delaware, fiscal year ends December
Schedule C Used to update any owner changes since last filing
Item 11 Yes to 11E(2); files a DRP for a prior FINRA rule finding
Item 12 BDR, USG, TRA (unchanged from existing filing)
Salesperson U4s Files a Form U4 marking Washington for each WA supervisor
Fee $160 original Washington registration drawn from CRD account
Execution Electronic execution through CRD (amendment, not first paper filing)

Scenario 3 — Non-FINRA limited broker-dealer filing paper. Evergreen Capital Partners, a small firm that qualifies for an exemption from SEC and FINRA membership, files paper with the DFI director.

Form Section What Evergreen Capital Enters
Application/Amendment Checks APPLICATION
Item 1A Evergreen Capital Partners LLC
Item 2 (SRO) Leaves FINRA unchecked; checks Washington only
Item 3A Limited Liability Company, formed in Washington
Schedule A & B Lists direct owners (5%+) and indirect owners (25%+)
Item 11 No to all parts; no DRPs
Item 12 PLA (private placements only)
Cover letter States limited registration sought and why no SEC/FINRA registration
Financials Balance sheet within 120 days plus net capital computation
Fee $160 check made out to state treasurer
Execution Original signed and notarized Page 1, mailed to DFI

How to File the Completed Form

Washington offers two filing channels, and the one you use depends on whether you are a FINRA member. Choose carefully, because sending a non-FINRA paper filing into CRD, or a FINRA filing on paper to the state, will bounce your application.

FINRA members — file through CRD / FINRA Gateway. Submit your Form BD, designate Washington in Item 2, and pay the fee electronically through FINRA Gateway. The Washington original registration fee is $160 under WAC 460-05A-010, with an $85 annual renewal, and each salesperson registration is $50 original and $30 renewal; these are drawn from your funded CRD account, and your proof of filing is the CRD confirmation and electronic receipt. Processing is typically a few weeks once the filing is complete, though disclosure events extend it.

Non-FINRA members — file paper with the DFI director. Mail the full paper Form BD with an original signed and notarized Execution Page, a cover letter, a balance sheet and net capital computation, exam proof, and a check for $160 made payable to state treasurer to the Washington DFI Securities Division at the address listed on its site. There is no online portal for the non-FINRA state filing, so certified mail with return receipt is the best way to document your submission. Keep the green card or tracking record and a full copy of the package as your proof of filing.

For either channel, the director may request more information under RCW 21.20.050 before approving the registration. If your application is denied or withdrawn, the director keeps half of the fee, so an incomplete filing has a real cost.

What Happens After You File

Once your filing is in, the DFI Securities Division reviews it for completeness and reviews any disclosure events on the firm or its control affiliates. For a clean FINRA-member filing with no disclosures, registration often becomes effective within a few weeks, and you can confirm status through CRD. The director may issue a deficiency letter asking for missing schedules, exam proof, or financial statements, and the review clock effectively pauses until you respond.

After registration, your obligations do not stop. You must promptly amend Form BD whenever a material change occurs, under WAC 460-20C-060, including changes in name, ownership, control, officers, branch offices, type of business, net capital problems, or new criminal charges and regulatory actions. FINRA members file these amendments through CRD, while non-FINRA firms send amended forms directly to the director.

You must also keep your people current: notify the director of any new Washington salesperson on Form U4 within 21 days, and report any termination on Form U5 within 30 days. Your registration then renews each year for the $85 firm fee, and letting it lapse means you are no longer authorized to do business in the state.

Mistakes to Avoid When Filling Out the Form

Each mistake below has stopped real applications, so check your form against the list before you file.

  • Forgetting to check the Washington box in Item 2 means the state never receives your registration request.
  • Using a P.O. Box in Item 1E causes the form to reject the main address outright.
  • Entering the wrong or another firm’s CRD number attaches your filing to the wrong record.
  • Omitting a 5% direct owner from Schedule A creates a material omission that can void registration.
  • Omitting a 25% indirect owner from Schedule B hides the real control chain and triggers denial.
  • Answering No on an Item 11 disclosure to hide an event turns a survivable matter into possible fraud.
  • Failing to file a DRP after a Yes answer leaves the filing incomplete and stalls review.
  • Submitting a photocopied or unsigned Execution Page on a first filing gets the package rejected.
  • Checking AMENDMENT on a true initial application leaves CRD with no record to attach to.
  • Sending a non-FINRA paper filing into CRD, or a FINRA filing on paper to the state, routes it to the wrong place.
  • Skipping the non-FINRA cover letter and net capital computation produces an automatic deficiency letter.
  • Checking too many Item 12 business types subjects you to net-capital expectations you never intended.

Do’s and Don’ts

Do’s

  • Do use the current SEC version of Form BD, because CRD rejects outdated copies.
  • Do enter your firm name exactly as it appears in your formation documents, since the agency cross-checks corporate records.
  • Do list every officer and 5% owner on Schedule A, because completeness is what the director verifies first.
  • Do disclose every Item 11 event and explain it on a DRP, since honesty is judged more kindly than concealment.
  • Do keep a stamped or electronic copy of the full filing, because it is your only proof of timing.
  • Do respond fast to any deficiency letter, since the review clock pauses until you do.

Don’ts

  • Don’t put a P.O. Box in the Item 1E main address, because the field bars it and the form bounces.
  • Don’t answer Item 5 Yes without first contacting CRD, since successions must be coordinated in advance.
  • Don’t guess at ownership percentages, because the wrong ownership code misstates control.
  • Don’t name an unauthorized junior employee as the Item 1H contact, since that person must route compliance mail.
  • Don’t let your annual renewal lapse, because an expired registration ends your authority to do business.
  • Don’t assume an electronic signature works on the first paper filing, since the initial Page 1 needs wet ink and notarization.

Pros and Cons of Filing on Your Own vs. With Help

Pros of filing on your own

  • You save the cost of a compliance consultant or securities attorney, which matters for a lean startup firm.
  • You learn your own firm’s structure in detail, which helps with later amendments.
  • You control the timeline directly rather than waiting on an outside advisor.
  • You build an in-house compliance habit early, which examiners value.
  • You avoid sharing sensitive ownership and disclosure data with a third party.

Cons of filing on your own

  • A single Item 11 misjudgment can trigger a denial that a specialist would have prevented.
  • Schedule A and B ownership rules are easy to misread, and errors there are serious.
  • Non-FINRA financial requirements (net capital, surety bond) are technical and unforgiving.
  • A deficiency letter can cost you weeks that experienced help would have avoided.
  • You bear full responsibility for the criminal-liability warning on Page 1 without a second set of eyes.

FAQs

Do I file Form BD through CRD or directly with Washington DFI?

Yes if your firm is a FINRA member you file through CRD; if your firm is not a FINRA member, you file the paper Form BD directly with the DFI Securities Division director.

Is there a fee to register a broker-dealer in Washington?

Yes. The original registration fee is $160 and the annual renewal is $85, under WAC 460-05A-010, and the director keeps half if the application is denied or withdrawn.

Do I write a P.O. Box in the Item 1E main address field?

No. Item 1E requires a physical street address and the form prohibits a P.O. Box there; you may list a P.O. Box only in the Item 1F mailing address.

Do I check the Washington box in Item 2 even if I checked the SEC box?

Yes. Checking the SEC box does not register you with any state, so you must separately check the Washington jurisdiction box for the state to receive your filing.

Do I list a 5% owner on Schedule A or Schedule B?

Yes, on Schedule A, which captures direct owners and executive officers at the 5% threshold; Schedule B is for indirect owners holding 25% or more up the ownership chain.

Do I report an old or expunged disciplinary event in Item 11?

Yes, in most cases, because Item 11 uses defined terms that often capture old or out-of-state matters; disclose and explain on a DRP rather than risk a false-statement finding.

Do I need an original signature on the Execution Page for my first filing?

Yes. The first paper Form BD filed with CRD requires an original, manually signed and notarized Execution Page; later amendments are executed electronically.

Do non-FINRA firms have to send financial statements?

Yes. Non-FINRA filers must include a balance sheet dated within 120 days plus a net capital and aggregate indebtedness computation, under WAC 460-20C-030 and WAC 460-20C-110.

Do I file a new application or an amendment to add Washington?

No new application is needed if your firm is already in CRD; you file an amendment to Form BD that adds Washington in Item 2.

Do I check Item 12 boxes for business I only plan to do later?

Yes, if you genuinely intend to do it and it will be at least 1% of revenue; do not check categories that are pure speculation, because examiners hold you to them.

Do I have to register my salespersons separately?

Yes. Each Washington salesperson or supervisor files a Form U4 marking Washington, with a $50 original fee, in addition to the firm’s Form BD.

Do I need to update Form BD after I am registered?

Yes. You must promptly amend Form BD for any material change under WAC 460-20C-060, including changes in ownership, officers, branch offices, net capital, or new regulatory actions.