Investment adviser firms can now access to their Preliminary Renewal Statement for 2024 through their IARD (Investment Adviser Registration Depository) accounts.
It’s crucial for the chief compliance officer (“CCO”) of an investment adviser firm to take note of the following dates and actions required for a smooth licensing renewal process:
- Preliminary Renewal Statement Payment Deadline: The Preliminary Renewal Statement must be paid in full by Monday, December 11, 2023.
- Payment Processing Time: Depending on your chosen method of payment, it may take at least two business days for the payment to be processed and reflected in your IARD account. To ensure that your investment adviser firm’s funds are successfully posted to your IARD account by the deadline, it is advisable that your payment arrives at FINRA no later than Wednesday, December 6, 2023.
Automatic Termination for Failure to Renew
It’s important for a CCO to be aware that most state securities regulators participate in the IARD Automatic Failure to Renew Program. Under this program, if your firm or its representatives are registered or notice filed in a jurisdiction that participates, the state securities regulator has granted FINRA the authority to automatically terminate the registrations of your investment adviser firm and its investment adviser representatives on December 31, 2023, if the firm’s IARD Renewal Account is not funded by the renewal deadline.
Every year, there are unfortunately instances where investment adviser firms fail to submit their renewal fees through their IARD accounts in a timely manner. In such cases, almost all state securities regulators will automatically terminate these registered firms and their representatives for non-payment. Dealing with the aftermath of such a situation can be time-consuming and costly.
For an investment adviser firm which does not properly renew, a state securities regulator may seek a fine and/or require a new registration application. Additionally, the state securities regulator might prohibit the investment adviser firm and its investment adviser representatives from charging of investment advisory fees while unregistered.
Available to Assist with Your Renewals
To help avoid problems with your investment adviser’s annual licensing renewals, learn more our about services by visiting 2024 IARD Renewal & Form ADV Annual Amendment Services.
The information contained in this blog post is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic. This is merely a summary and does not necessarily include all topics covered in the regulator’s guidance. RIA Compliance Consultants, Inc. is not offering any safe harbor, guarantees nor other assurances associated with the example questions that an examiner may consider related to informed consent. The content of this blog post may become dated and inaccurate; RIA Compliance Consultants, Inc. does not typically update past posts. This post is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s order, rules and published guidance for more details about the topics referenced above. RIA Compliance Consultants, Inc. is not a law firm and does not provide legal services. For more information about the limitations of this blog post and information on our website, please see our Disclosures webpage.