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The following is not meant to be legal advice.

Those working for a broker-dealer in compliance may be familiar with Temporary Agent Transfer (TAT). 

There is a minimum number of business days to TAT someone.  It used to be 5 business days.  TAT means to transfer someone’s license from one firm to another.  If it is over the 5 business days, the new employer needs to turn in a U-4 and process the representative the normal way.  This may take 1-2 weeks to approve, and takes longer than the TAT. 

A U-4 cannot be turned in to the NASD prior to the person’s start date with a firm.  The new firm may put an earlier start date to use for TAT and not allow the person to sell until he/she is actually on the payroll.  The TAT start date may be different from the start date on the payroll.

California and DC did not used to participate in the TAT program.  In California, representatives were required to only get registered within 30 days after the start date they did business in California.  The representative could be TAT for the NASD, but not California. 

When a firm TATs an employee, the firm should firs check that it has money in its account to do the TAT.  Then, check with the old firm to make sure there are no “yes” answers in the U-5.  Verify the termination date on the U-5.  In order to TAT, there must be no disciplinary actions, or bankruptcies.