Monday, December 12 is the last day to submit payment to your IARD Renewal Account in order to ensure the necessary fees are received by the NASD and posted to your investment advisor firm’s account by Wednesday, December 14, the final deadline to have preliminary renewal fees paid.
According to the NASD, failure to submit payment by this deadline will result in the automatic termination of all investment advisor representatives. In addition, thirty-six states and the District of Columbia are participating in the Automatic Failure to Renew Program for 2006. This means if your firm is registered or notice filed in one of the participating states and your firm fails to pay its renewal fee, the firm’s approval status in the participating states will automatically be terminated. Needless to say, it is imperative to submit full payment to the NASD by Monday. Even if changes have been made to your account since the Preliminary Renewal Statement was posted, you must fund the entire amount due on the statement. Adjustments will be reflected on the Final Renewal Statement which will be posted on January, 3, 2006.
Once you have submitted the entire renewal fee due, you need to ensure the fees are posted correctly to your account. You can ensure payment has been received by checking your firm’s Renewal Account Summary Activity. The balance should indicate a sufficient status and a negative amount posted. Keep in mind that a negative amount actually indicates a positive amount of money in the account. In the past there have been cases of funds being posted to the Daily Account and not the Renewal Account. There have also been instances where payment has been submitted to the wrong account altogether.
As noted above, the Final Renewal Statement will be posted on January 3, 2006. The Final Renewal Statement will reflect changes that are made from November 21 through December 21 which is the last day electronic Form U4s, Form U5s, Form ADVs, and Form ADV-Ws can be filed for 2005. The IARD/CRD system will reopen on January 3 at which time amendments may be submitted. During the shutdown period, advisor firms will be able to view information on the system and create pending applications; however, the submission functionality will be disabled.
More information about the 2006 Renewal Season can be attained at the IARD website.