The Preliminary Renewal Statement should now be available in the investment adviser firm’s IARD account.
As an investment adviser firm reviews the Preliminary Renewal Statement, it should consider whether the 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.
In order to receive a refund on the Final Renewal Statement, the investment adviser firm must file the withdrawal request (Post-Dated Termination Notice) via the IARD system by no later than the last day in the calendar year for IARD filings (for example, you will need to file no later than 6:oo p.m. Eastern U.S. on Tuesday, December 26, 2023 to receive a refund for calendar year 2024). An investment adviser firm will not receive partial or pro-rata refunds for withdrawing state registrations and state notice filings on or after the first business day of the new calendar year (January 2, 2024 for calendar year 2024); no refunds will be issued by the state securities regulator if the Form ADV-W or Form ADV Amendment is filed after the last-day IARD filing date (December 26, 2023 for calendar year 2024).
Although an investment adviser firm may file such a Form ADV-W or Form ADV amendment removing the state registration or notice filing, the investment adviser firm still must pay the Preliminary Renewal Statement in full, by the due date for Preliminary Renewal Statements (Monday, December 11, 2023 for calendar year 2024). The investment adviser firm will not receive credit for any refunds until the Final Renewal Statement.
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 of this topic. Securities regulations and corresponding deadlines are subject to change, and this calendar event may not reflect the most current requirements. This calendar event 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 rules and published guidance for more details and the most current requirements about the topics referenced above.