Now that we are into a new year, can you confirm your registered investment advisor and its advisor representatives were properly renewed for 2008? Every year there are always a handful of firms that fail to submit renewal fees through the IARD system in a timely fashion. Therefore, even if you think the renewal payment was sent in time, please make sure your firm retrieves the Final Renewal Statement and confirms it is renewed for calendar year 2008.
The Final Renewal Statement will indicate one of the following.
1. Paid in Full – If your firm’s renewal statement has been paid in full, the renewal process is complete. You should print a copy of the Final Renewal Statement and file it with your firm’s books and records.
2. Outstanding Balance Due or Refund – If your firm paid its Preliminary Renewal Statement in full, but added or removed a state registration or advisor representative during the time period between the posting of Preliminary Renewal Statements and the 2007 shut down period, then your firm will either have additional fees due or receive a credit. If additional fees are due, the fees should be submitted as soon as possible, but must be posted by February 4, 2008. If your firm received a refund, the credit will automatically be transferred to your firm’s Daily Account.
3. Failed to Renew – If a firm’s Final Renewal Statement indicates Failed to Renew, FINRA did not receive the total balance due on the Preliminary Renewal Statement prior to the December deadline. In these cases, it is standard operating procedure for FINRA to automatically terminate all advisor representatives of the firm. In addition, over thirty states have given FINRA the authority to automatically terminate a registered investment advisor that does not pay its renewal fees in full. If your firm’s statement indicates Failed to Renew, you will need to contact each state jurisdiction immediately to determine an appropriate course of action.
Finally, it is important to make sure your registered investment advisor submits all required documentation directly to the states where the firm is registered.
If your firm did fail to renew through IARD, please give us a call to find out more about our registration services and pricing.
Posted by Bryan Hill