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.
Posted by RCC
Labels: ADV Part 3, Annual Amendment, IARD
