As annual renewal season rapidly approaches, investment advisers should be proactive and begin preparing for renewals by reviewing to make sure the investment advisor is properly registered or notice filed, as applicable, and that its investment adviser representatives are properly licensed with all required state securities regulators. The IARD Renewal Program serves to facilitate the annual renewal of investment advisers and their investment adviser representatives’ registrations with the appropriate state securities regulators. Although, an investment adviser’s registration, notice filing, and licensing requirements is something that should be reviewed and monitored on an ongoing basis, during the annual renewal process all investment advisers should review their existing registration or notice filing status and each investment adviser representative’s licensing status to confirm that the investment adviser and its representatives are properly registered, notice filed, or licensed (as applicable). Additionally, all state registered investment advisers should also review the state requirements to see if branch office registration is required and, if it is, investment advisers should confirm that all branch office locations have been properly registered.
It is imperative that registered investment advisers ensure they are properly registered or notice filed at all times and that its investment adviser representatives are properly licensed at all times. State investment adviser registrations and notice filings and investment adviser representatives’ licensing statuses expire every year on a calendar basis. All renewal fees are paid during the IARD renewal season. While the U.S. Securities and Exchange Commission (“SEC”) does not charge a registration fee, SEC registered investment advisers must pay the appropriate state fees to notice file with all required state securities regulators and to properly register the investment advisers’ representatives with the required state securities regulators.
In accordance with the 2016 IARD Renewal Program Calendar investment adviser firms are encouraged to “review their registered persons to ensure that they have properly and timely reported all appropriate information to Web CRD® and that all open branch offices have individuals assigned to them and they are accurately reported.”
If your investment adviser firm needs assistance with the renewal process or determining if it is properly registered, RIA Compliance Consultants can assist you. If you are an existing client of RIA Compliance Consultants, please contact your consultant to discuss how we can assist you. If you have not previously worked with RIA Compliance Consultants, please click here to learn more about our 2016 IARD Renewal and Form ADV Annual Amendment Services or click here to schedule a time to speak with one of our consultants.