Certain state securities regulators have additional renewal requirements beyond the IARD renewal statements and Annual Form ADV Amendment.
In particular, there are states securities regulators that require its state-registered investment adviser firms to submit annual financial statements and/or other documents directly to the state securities regulator (outside of the IARD/CRD system). Requirements vary significantly among states – some state securities regulators require all state registered investment adviser firms filed in the state to submit an annual financial statement while other state securities regulators may only require the submission of an annual financial statement if the investment adviser firm has a principal place of business in the state, maintains investment discretion or is deemed to have custody of client assets.
These annual submissions (outside of the IARD/CRD system) of the financial statement and/or other documents to a home state securities regulator are most commonly due at the end of the calendar year (December 31) or within 90 days of the end of an investment adviser’s fiscal year. However, each state has its own deadline, so it is important to check directly with the states where your investment adviser firm is registered.