Now that we are into a new year, can you confirm your registered investment adviser firm and its investment adviser representatives were properly renewed for 2015? Every year there are always a handful of investment adviser 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 investment adviser firm retrieves the Final Renewal Statement and confirms it is renewed for calendar year 2015.
The Final Renewal Statement will indicate one of the following.
Paid in Full – If your investment adviser 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 investment adviser firm’s books and records.
Outstanding Balance Due or Refund – If your investment adviser firm paid its Preliminary Renewal Statement in full, but added or removed a state registration, notice filing or investment adviser representative during the time period between the posting of Preliminary Renewal Statements and the 2015 shut down period, then your investment adviser 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 January 16, 2015. If your firm received a refund, the credit will automatically be transferred to your investment adviser firm’s Flex-Funding Account.
Failed to Renew – If an investment adviser 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 investment adviser representatives of the investment adviser firm. In addition, forty-four state securities regulators have given FINRA the authority to automatically terminate a registered investment adviser that does not pay its renewal fees in full. If your investment adviser firm’s statement indicates Failed to Renew, you will need to contact each state securities regulator immediately to determine an appropriate course of action. Please be advised that many state securities regulators level fines for failure to renew properly.
It is important to make sure your registered investment adviser firm submits any additional required annual documentation directly to the state securities regulators where the firm is state registered. If your investment adviser firm failed to renew through IARD, it is important to take immediate action to rectify the situation. Give us a call at 877-345-4034 to find out more about our re- registration services and pricing.