Failure to Properly Renew Registration may Result in Adverse Consequences for Investment Advisers

October 22, 2013

Investment adviser firms and investment adviser representatives must maintain active registrations and/or notice filing statuses with applicable jurisdictions/states. Unless properly renewed, all investment adviser firm and investment adviser representative licensing approvals expire on December 31 of each calendar year. In order to ensure investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2014, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.

Failure to maintain active registration or failing to properly renew registration may be detrimental to an investment advisor firm.  Investment adviser firms and investment adviser representatives that are not properly renewed may become ineligible to conduct business effective January 1, 2014.  Additionally, certain regulators may assess fines against those firms or representatives that fail to properly renew.

Most jurisdictions participate in the IARD Automatic Failure to Renew Program.  If your investment adviser firm or representatives are registered or noticed filed in a jurisdiction that participates in the IARD Automatic Failure to Renew Program, your jurisdiction has authorized FINRA to automatically terminate your investment adviser firm and investment adviser representative registrations on December 31, 2013, if your IARD account was not funded in full by the Renewal Deadline.  As of September 28, 2012, 44 Jurisdictions are participating in the IARD Automatic Failure to Renew Program. Additionally, as mentioned, many jurisdictions levy fines for failure to renew properly.

Beginning November 11, 2013, your investment adviser may retrieve your firm’s Preliminary Renewal Statement using the IARD/Web CRD system. Your investment adviser’s Preliminary Renewal Statement will reflect the full payment your investment adviser firm must provide to FINRA by Friday, December 13, 2013.

If your investment adviser needs assistance with the renewal process or determining if it is properly registered, RIA Compliance Consultants can assist you. Depending on your needs, RIA Compliance Consultants offers a variety of services to assist with the annual renewal process and preparing and filing the Form ADV Part 1 annual amendment.  If you are an existing client of RIA Compliance Consultants interested in engaging us for assistance with these services, please contact your consultant to discuss the package options available. If you are a new client interested in these services, please click here to learn more about our renewal services, or click here to schedule a time to speak with one of our consultants.

Posted by Bryan Hill
Labels: IAR Licensing, IARD, Renewals