Investment Advisers Should Begin Preparations for 2020 Renewals

October 29, 2019

As annual renewal season rapidly approaches, investment advisers should be proactive and begin preparing for renewals by reviewing to make sure the investment adviser 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 are some things 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 2020 IARD Renewal Program Calendar, as of October 7, 2019, investment adviser firms were encouraged to “review their registered persons to ensure that they have properly and timely reported all appropriate information to Web CRD® and IARD™ and that all open branch offices have individuals assigned to them and are accurately reported.”

RIA Compliance Consultants can assist your investment adviser with the annual renewal process and help with preparing and filing the Form ADV annual update amendment when the time comes. This year the fee for our 2020 IARD Renewal and Form ADV Annual Amendment package purchased prior to December 9, 2019 will be $1,095*. Engagement of RCC after December 9, 2019 will be subject to availability and additional fees will be charged.

Additionally, if you are an SEC registered investment adviser firm, RIA Compliance Consultants will be offering an investment adviser Client Relationship Summary/Form ADV Part 3 (“Form ADV Part 3”) drafting service for $595 subject to certain restrictions (see engagement agreement letter linked here for those restrictions). The $595 drafting service will only be available if you purchase the service and execute a letter of engagement prior to April 1, 2020. After March 31, 2020 these services will be subject to availability and prices will increase. Again, the Form ADV Part 3 is only applicable to SEC registered firms. After March 31, 2020 these services will be subject to availability and prices will increase.

  • Click here to purchase IARD Renewal and ADV Annual Amendment Services.
  • Click here to purchase IARD Renewal, ADV Annual Amendment, and Form ADV Part 3 Drafting Services.

Once you have made the online purchase, you will receive the engagement letter via email. Click here if you would like to view the engagement letter for the IARD Renewal and ADV Annual Amendment Services and click here if you would like to view the engagement letter for the IARD Renewal, ADV Annual Amendment, and Form ADV Part 3 Drafting services. Please keep in mind that we must receive the retainer payment and executed engagement letter prior to December 9, 2019 in order to be eligible for the discount on the IARD Renewal and ADV Annual Amendment services.

Don’t miss the opportunity to have RIA Compliance Consultants guide you through your renewals to make sure you remain properly registered for 2020, assist you with your Form ADV annual amendment to meet your regulatory obligation, and, if applicable, assist you with drafting your Form ADV Part 3. Sign-up now and take advantage of the discount for our 2020 IARD Renewal and Form ADV Annual Amendment services.

*NOTE: Firms managing private funds may be charged additional fees. If you manage one or more private funds, please contact us to discuss the fee prior to engaging RIA Compliance Consultants for the 2019 IARD Renewal and Form ADV Annual Amendment package.

Posted by Grant Parr
Labels: ADV Part 3, Annual Amendment, IARD