State disclosure review & Branch office registration in Florida

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Dec 10, 2010 8:26 am

Did you know that the states often will reserve their review of a Rep's CRD when they go to relicense (i.e., leave a firm and registered with a new firm)?  For example, in Florida if you've been with BD A for 10 years and got a customer complaint disclosure within the last 2 years, chances are Florida would not have reviewed that complaint (unless the customer complained directly to the state).  If you leave BD A to join BD X and re-register in Florida, your re-registration is subject to manual review meaning that you will not be automatically "tat'd" or approved in Florida.  The state's review can take anywhere from a few weeks to 3 months, depending on the amount of disclosures that occurred while at BD A and the severity of them.  This is an important consideration when considering to jump ship, take the up front money and set up new shop.  Florida has become the worst state for unclean CRDs (i.e., at least one disclosure -- one hit) relicensing in the state.  The scrutiny is even regardless of domicile.  

Also, in Florida, for independents, if you change firms the state has to approve your branch office's registration at the the new firm and the process can take as long as 2 weeks!  The form is called Form BR that the firm handles.  The state is aware of the antiquated review process but has made little progress in the handling of Form BR registration.  What does this mean to you?  If you leave Indie BD 1 to go to Indie BD 2 and assuming your CRD is clean, you could be out of business for up to 2 weeks!  If your CRD has a Yes to it, then I can't predict the turnaround time.  Reply if you'd like my thoughts on a legal, compliant work around to the branch re-registration issue.