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.
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.
RIA Compliance Consultants recommends the chief compliance officer (“CCO”) of your investment adviser firm add the following deadlines for IARD renewals and the annual Form ADV amendment to his or her calendar:
Your investment adviser firm can create IARD renewal email alerts in E-Bill section of the IARD account. The email alerts sent to your investment adviser firm can include notifications about renewal statements, deadlines, or confirmation that your investment adviser firm has paid its renewals in full. The Super Account Administrator (“SAA”) for your investment adviser firm’s IARD account does not automatically receive all the available alerts; the SAA must subscribe for the various email alerts. For more details about the features of the E-Bill section of your investment adviser firm’s IARD account, visit E-Bill Frequently Asked Questions (FAQ) at https://www.finra.org/filing-reporting/e-bill/faq#alerts .
November 12, 2019
As you review your investment adviser firm’s Preliminary Renewal Statement from the IARD system, your investment adviser firm should consider whether its investment adviser representatives should be registered as an investment adviser representative in a particular state.
November 11, 2019
As you review your investment adviser firm’s Preliminary Renewal Statement from the IARD system, you should consider whether your investment adviser firm desires to terminate a firm-level investment adviser state registration or state notice filing so it can receive a regulatory fee refund.
The Securities Bureau of the Nebraska Department of Banking and Finance has released its 2020 list of requirements for a state-registered investment adviser (IA) and an investment advisor representative (IAR) to renew their registration in the State of Nebraska.
November 07, 2019
Starting Monday, November 11, 2019, a registered investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for 2020 renewals. The Preliminary Renewal Statement must be paid, in full, by Monday, December 16, 2019. 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 11, 2019, to ensure that funds are posted to your firm’s IARD account by December 16, 2019.
October 29, 2019
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.