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).
December 03, 2020
The deadline for investment advisers to submit their Preliminary Renewal Statement payment is quickly approaching. FINRA must be in receipt of the full payment listed on the Preliminary Renewal Statement by December 14, 2020. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning on December 14, 2020 to the Renewal Account to cover total renewal fees owed. Automatic transfers will be conducted every day after December 14, 2020 until the WEB CRD/IARD shuts down for year-end processing on December 27, 2020. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline. If your investment adviser would like assistance with the annual renewal service, click here for more information on or to purchase RIA Compliance Consultants’ IARD Renewal Program and ADV Amendment Service. If you have questions regarding these or any of the other services offered by RIA Compliance Consultants, contact your support person or our business development team at firstname.lastname@example.org
November 19, 2020
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.
November 18, 2020
As of Monday, November 16, 2020, your investment advisor firm can access, via its IARD account, its Preliminary Renewal Statement for the upcoming year. Investment advisor firms are assessed individual registration fees based on the state(s) that the firm is notice filed or registered in and the number of investment advisor representatives and their approved registration statuses. The amount reflected in the Preliminary Renewal Statement is the amount of renewal fees investment advisors must pay in order to maintain active registration for the firm and its investment advisor representatives.
November 12, 2020
Starting Monday, November 16, 2020, a registered investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for 2021 renewals. The Preliminary Renewal Statement must be paid, in full, by Monday, December 14, 2020. 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 9, 2020, to ensure that funds are posted to your firm’s IARD account by December 14, 2020.
October 28, 2020
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 2021, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.
October 14, 2020
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.
An investment adviser firm’s Final Renewal Statement reconciles what was charged on the Preliminary Renewal Statement with what is actually owed as the start of the new calendar year (January 1, 2020). The Final Renewal Statement confirms whether an investment adviser firm must pay an additional amount, received a refund (i.e. credit) to its Flex-Funding Account or is Paid-in Full.
December 08, 2019
The deadline for investment adviser firms to submit their Preliminary Renewal Statement payment is quickly approaching. FINRA must be in receipt of an investment adviser firm’s full payment listed on the Preliminary Renewal Statement by December 16, 2019. Investment adviser firms with sufficient funds in their IARD Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning on December 16, 2019 to the IARD Renewal Account to cover total renewal fees owed. Automatic transfers will be conducted every day after December 16, 2019 until the WEB CRD/IARD shuts down for year-end processing on Friday, December 27, 2019. Investment adviser firms that choose to mail in their renewal payments are advised to do so now to avoid delays and to ensure funds are received by the deadline.
December 02, 2019
Certain state securities regulators have additional renewal requirements beyond the IARD renewal statements and Annual Form ADV Amendment.