As a chief compliance officer (“CCO”) reviews his or her investment adviser firm’s Preliminary Renewal Statement from the IARD system, the CCO should consider whether his or her investment adviser firm desires to terminate a firm-level investment adviser state registration or notice filing with a state securities regulator so the firm can receive a regulatory fee refund.
In order to receive a refund on the Final Renew Statement, the investment adviser firm must file the withdrawal request via the IARD system by no later than Saturday, December 26, 2020. Otherwise, the investment adviser firm’s state registration or notice filing will be renewed in each state for 2021.
The investment adviser firm will not receive partial or pro-rata refunds for withdrawing state registrations and state notice filings on or after January 2, 2021; no refunds will be issued by the state securities regulator if the Form ADV-W or Form ADV Amendment is filed after December 26, 2020.
Although an investment adviser firm may file (before December 26, 2020) a Form ADV-W or Form ADV amendment removing the state registration or notice filing, the investment adviser firm still must pay the Preliminary Renewal Statement in full, by Monday, December 14, 2020, which means the CCO will want to make sure that the funds arrive at FINRA a few days before the deadline so they can be properly credited to the firm’s account. The investment adviser firm will not receive credit for any refunds until the Final Renewal Statement in January 2021.
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