The deadline for investment advisers to submit their Preliminary Renewal Statement payment is quickly approaching. FINRA must be in receipt of the full payment listed on the Preliminary Renewal Statement by December 17, 2018. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning on December 17, 2018 to the Renewal Account to cover total renewal fees owed. Automatic transfers will be conducted every day after December 17, 2018 until the WEB CRD/IARD shuts down for year-end processing on December 27, 2018. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline. If your investment adviser would like assistance with the annual renewal service, click here for more information on or to purchase RIA Compliance Consultants’ IARD Renewal Program and ADV Amendment Service. If you have questions regarding these or any of the other services offered by RIA Compliance Consultants, contact your support person or Amanda Erwin (877) 345-4034 Ext. 115.
Ensure Timely Preliminary Renewal Statement Payments
November 20, 2018
Don’t wait until the last minute to submit your annual renewal fees. FINRA must be in receipt of the full payment listed on the Preliminary Renewal Statement, which is now available, by Monday, December 17, 2018. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning December 17, 2018 to the Renewal Account to cover total renewal fees owed. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline. If your investment adviser would like assistance with the annual renewal service, click here for more information on or to purchase RIA Compliance Consultants’ IARD Renewal Program and ADV Amendment Services.
Preliminary Renewal Statement Now Available
November 15, 2018
As of Monday, November 12, 2018, your investment advisor firm can access, via its IARD account, its Preliminary Renewal Statement for the upcoming year. Investment advisor firms are assessed individual registration fees based on the state(s) that the firm is notice filed or registered in and the number of investment advisor representatives and their approved registration statuses. The amount reflected in the Preliminary Renewal Statement is the amount of renewal fees investment advisors must pay in order to maintain active registration for the firm and its investment advisor representatives.
Preliminary Renewal Statements Available Monday
November 07, 2018
Starting Monday, November 12, 2018, a registered investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for 2019 renewals. The Preliminary Renewal Statement must be paid, in full, by Monday, December 17, 2018. Depending on your method of payment, it may take at least two days for a payment to post to the IARD account. Because of this, your firm’s payment should arrive at FINRA no later than Wednesday, December 12, 2018, to ensure that funds are posted to your firm’s IARD account by December 17, 2018.
Annual Renewals of Investment Advisers is Quickly Approaching
November 02, 2018
Now is the time for each registered investment adviser to begin preparations for IARD renewals for the investment adviser firm and its investment adviser representatives. Registered investment advisers must make sure that they always remain properly registered. If you are an SEC registered investment adviser, you must make sure that your investment adviser is notice filed in all required states. If you are a state registered investment adviser, you must make sure your investment adviser is properly registered in all required states. Generally, registration or notice filing is required at the firm level if an investment adviser has a place of business in the state or if it exceeds the state’s de minimus exemption. However, investment advisers must review each state’s notice filing or registration requirements prior to conducting business in a state. Investment adviser representative licensing is always handled at the state level. Investment adviser firms must review and determine that all investment adviser representatives are properly licensed prior to conducting business in a state.
California Securities Regulation Division Is Currently Conducting Online Examinations of State Registered Investment Advisers
October 25, 2018
RIA Compliance Consultants was recently made aware that the California Department of Business Oversight – Securities Regulation Division is conducting “Online Written Examinations” of investment adviser firms registered with the State of California regardless of whether or not the investment adviser firm has offices located in California.
Spreadsheet for Investment Adviser to Document that Authority to Initiate First-Party Transfer Between Different Custodians Doesn’t Constitute Custody
October 22, 2018
Does your federally registered investment adviser firm have authority to initiate first-party transfers between the client’s accounts at different qualified custodians?
The Indiana Securities Commissioner recently published a new Statement of Policy regarding custody requirements for investment adviser firms registered in Indiana.
SEC Fines Investment Adviser for Cybersecurity Failures
October 09, 2018
The United States Securities and Exchange Commission (SEC) has recently fined an Iowa-based investment adviser $1 million for alleged cybersecurity failures that led to a data breach that compromised the personal information of its clients. According to the SEC, information from over 5,600 of the investment adviser’s clients was obtained by criminals impersonating independent advisers. The SEC claims that the intruders gained access through weaknesses within the firm’s cybersecurity procedures. Some of these weaknesses had been exposed during previous fraudulent activity. The investment adviser allegedly failed to update and fix those issues.
SEC Settles Charges of Undisclosed Conflict in Advisory Decision
September 06, 2018
The U.S. Securities and Exchange Commission (“SEC”) recently announced that it has settled charges with an investment adviser firm. The SEC alleged that the investment adviser failed to disclose a conflict of interest. The settlement ended in payment of $8.9 million to the SEC by the investment adviser.
