As of yesterday, Monday, November 16, 2015, your investment adviser firm can access, via its Investment Adviser Registration Depository (IARD) account, its Preliminary Renewal Statement for the upcoming year. Investment advisor firms are assessed individual registration fees based on the state(s) that the firm is notice filed or registered in and the number of investment advisor representatives and their approved registration statuses. The amount reflected in the Preliminary Renewal Statement is the amount of renewal fees investment advisors must pay in order to maintain active registration for the firm and its investment adviser representatives.
The Preliminary Renewal Statement must be paid, in full, by Friday, December 18, 2015. Since it takes approximately two (2) business days for payment to post to the IARD account, your firm’s payment should arrive at FINRA no later than Wednesday, December 16, 2015 to ensure that funds are posted to your firm’s IARD account by December 18, 2015
Unfortunately, every year there are investment adviser firms that fail to submit renewal fees through their IARD accounts in a timely fashion, and almost all state securities regulators will automatically terminate these registered investment advisor firms and their investment advisor representatives for failing to pay their renewal fees. The contacting of each state securities regulator after such a failure to renew can be time intensive and potentially expensive since a state securities regulator typically has the authority to require a new registration application and prohibit the charging of investment advisory fees as long as the firm and representatives are unregistered.
Many times investment advisors can find the IARD system difficult to use because they do not access it on a regular basis. It is also important to note that IARD Renewal payments are submitted to a different account than the account the investment advisor would normally submit payment to for a new registration. RIA Compliance Consultants can assist you with this process and save you the time of trying to figure out where to find your renewal reports and how to properly submit the renewal payments. We recommend that you utilize our IARD Renewal and ADV Annual Amendment Service. In addition to assisting you with the IARD renewal process, this service includes preparing and filing your investment advisor firm’s Form ADV Part 1 Annual Amendment, which is required to be filed within 90 days after the firm’s fiscal year. Click here to purchase our 2016 IARD Annual Renewal and Form ADV Annual Amendment Services.
To speak with one of our Consultants to see how we may further assist you, click here. If you are a current client of RIA Compliance Consultants, please contact your consultant directly.