Category Archives: Annual Amendment
 

Failure to Properly Renew Registration May Result in Adverse Consequences for Investment Advisers

October 19, 2023

Investment adviser firms and investment adviser representatives must maintain active registrations and/or notice filing statuses with applicable jurisdictions/states. Unless properly renewed, all investment adviser firm and investment adviser representative licensing approvals expire December 31 each calendar year. To ensure that investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2024, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.

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Don’t Stop at Form ADV Annual Amendment – Certain States Require Annual Financial Statement

February 07, 2023

Along with updating your Form ADV Annual Amendment, it’s important to remember that many state securities regulators also require state registered investment adviser firms to submit annual financial statements and/or other documents (e.g., proof of continued coverage of a surety bond, investment advisory client agreement if material changes) directly to the state securities regulator (outside of the IARD/CRD system).

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2023 Preliminary Renewal Statements Available Monday

November 02, 2022

Starting Monday, November 7, 2022, a registered investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for 2023 renewals. The Preliminary Renewal Statement must be paid, in full, by Monday, December 12, 2022. Depending on your method of payment, it may take at least two days for a payment to post to the IARD account. Because of this, your firm’s payment should arrive at FINRA no later than Wednesday, December 7, 2022, to ensure that funds are posted to your firm’s IARD account by December 12, 2022.

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Annual Renewals of Investment Advisers is Quickly Approaching

October 19, 2022

Now is the time for each registered investment adviser to begin preparations for IARD renewals for the investment adviser firm and its investment adviser representatives. Registered investment advisers must make sure that they always remain properly registered. If you are an SEC registered investment adviser, you must make sure that your investment adviser is notice filed in all required states.  If you are a state registered investment adviser, you must make sure your investment adviser is properly registered in all required states.  Generally, registration or notice filing is required at the firm level if an investment adviser has a place of business in the state or if it exceeds the state’s de minimis exemption.  However, investment advisers must review each state’s notice filing or registration requirements prior to conducting business in a state.  Investment adviser representative licensing is always handled at the state level.  Investment adviser firms must review and determine that all investment adviser representatives are properly licensed prior to conducting business in a state.

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Investment Advisers Should begin Preparing to Submit their Annual Form ADV Amendment

December 22, 2021

Annual Amendment ServiceInvestment Advisers’ Final Renewal Statements and reports will be available for viewing and printing on January 2, 2022. All registered investment advisers should download and review these reports; Final Renewal Statements will indicate if any additional fees are due and these payments are due by January 22, 2022. Additionally, investment advisers with a fiscal year end of December 31 are encouraged to begin preparing their required Form ADV annual updating amendments.

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Failure to Properly Renew Registration May Result in Adverse Consequences for Investment Advisers

October 29, 2021

Investment adviser firms and investment adviser representatives must maintain active registrations and/or notice filing statuses with applicable jurisdictions/states. Unless properly renewed, all investment adviser firm and investment adviser representative licensing approvals expire December 31 each calendar year. To ensure that investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2022, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.

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Regulatory Reminder – Submission of Annual Financial Statements in Certain States

February 25, 2021

As your state registered investment adviser firm completes its Form ADV Annual Amendment, it’s important not to forget that many state securities regulators also require a state registered investment adviser firm to submit annual financial statements and/or other documents (e.g., proof of continued coverage of a surety bond, investment advisory client agreement if material changes) directly to the state securities regulator (outside of the IARD/CRD system).

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