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Deadline for Payment of 2024 Preliminary Renewal Statement

The Preliminary Renewal Statement for an investment adviser firm must be paid, in full, by Monday, December 11, 2023. Depending on the method of payment, it may take at least two days for a payment to post to the IARD account.  RCC recommends submitting payment to FINRA by no later than Wednesday, December 6, 2023. […]

Last Day in CY23 to Make IARD/CRD Filing

The last day to submit registration filings (via IARD/CRD systems) prior to year-end is Tuesday, December 26, 2023. After 6:00 p.m. ET, IARD/CRD systems are unavailable.   General Disclosure: The information contained in this sample calendar event is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis […]

Final IARD Renewal Statement Is Available

An investment adviser firm’s Final Renewal Statement is available on the FINRA Gateway. The 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. The Final Renewal Statement confirms whether an investment adviser firm must pay an additional amount, received […]

Request/Verify Each Access Person’s Annual Holdings Report of Personal Securities

In general, an investment adviser firm's code of ethics requires each access person within the firm to submit annually to the firm's chief compliance officer ("CCO") or other designee a report of the access person's current personal securities holdings. Typically, the report must include the following information: The title and type of security, and as […]

Deadline for Payment of Final IARD Renewal Statement

If an investment adviser firm owes additional fees on the Final Renewal Statement, the investment adviser firm must pay by the Final Renewal Statement’s due date. Resources General Disclosure The information contained in this sample calendar event is general in nature intended for educational purposes only and is not intended to be a comprehensive […]

Form 13H Annual Filing Deadline

Under Section 13(h) of the Securities Exchange Act, Form 13H must be filed by any organization that is considered a large trader. An investment adviser firm qualifies as a “large trader” when the firm has discretionary authority over one or more accounts that purchase or sell any exchange-listed security in an aggregate amount equal to […]

Delivery of Form ADV Part 2A to Existing Clients

An investment adviser is required to deliver to each client, annually within 120 days after the end of the investment adviser’s fiscal year and without charge, if there are material changes to the investment adviser’s brochure since the investment adviser’s last annual updating amendment: (1) a current copy of the investment adviser’s disclosure brochure (Form […]

Request Supervised Persons Complete Annual Attestations

As compliance best practice and/or possibly a requirement under an investment adviser firm's compliance manual, each supervised person of the firm should submit the following items to the firm's chief compliance officer ("CCO") or designee on an annual basis: Each supervised person should confirm in writing that such individual has re-reviewed and understands the firm's […]

State Registered Firms – Verify Whether Annual Financial Statement Must Be Submitted to Regulator

Along with paying annual renewals via IARD system and updating your Form ADV Annual Amendment, it’s important to remember that many state securities regulators also require a state registered investment adviser firm to submit an annual financial statement and/or other documents (e.g., proof of continued coverage of a surety bond, investment advisory client agreement if […]