The North American Securities Administrators Association (NASAA) announced that the Investment Adviser Registration Depository System (IARD), the national database sponsored by NASAA and the U.S. Securities and Exchange Commission (SEC) that provides investment adviser firms and their investment adviser representatives a single source for filing state and SEC investment adviser registration and notice filings, will waive the IARD system processing fees for state registered investment adviser firms in 2016. While waiving IARD system processing fees for state registered investment adviser firms in 2016, NASAA will continue charging a $10 IARD system processing fee for each investment adviser representative (IAR).
Please understand that this waiver for the IARD system processing fees only applies to state registered investment adviser firms. SEC registered investment adviser firms will continue be subject to an IARD system processing fee based upon assets under management of the SEC registered investment adviser. For more details, please click here. It also important to note that the IARD system processing fees referenced above are separate from state registration and notice filing fees charged by state securities regulators. If you’d like to view a list of each state’s investment adviser registration or notice filing fee, please click here. Likewise, click here to view a list of each state securities regulator’s fee for investment adviser representative registration.
This announcement comes as annual renewal season for investment advisers approaches. RIA Compliance Consultants reminds investment adviser firms to be proactive and begin preparing IARD renewals for review to make sure the investment adviser firm is properly registered or notice filed and that all of its investment adviser representatives are properly licensed with all required state securities regulators. Although, an investment adviser’s registration, notice filing, and licensing requirements are things that should be reviewed and monitored on an ongoing basis, during the annual IARD renewal process all investment adviser firms 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 adviser firms 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.
RIA Compliance Consultants can assist your investment adviser with the annual renewal process and provide assistance with preparing and filing the Form ADV annual update amendment when the time comes. If you would like to engage RIA Compliance Consultants to assist you, click here to purchase this service. If you have questions or need to further discuss these services and you are an existing client of RIA Compliance Consultants, please contact your consultant to discuss the services available. If you are not a client but are interested in these services, please click here to schedule a time to speak with one of our consultants.