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

November 16, 2023

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 material changes) directly to the state securities regulator (outside of the IARD/CRD system).

Requirements vary significantly among states – some state securities regulators require all state registered investment adviser firms filed in the state to submit an annual financial statement while other state securities regulators may only require the submission of an annual financial statement if the investment adviser firm has a principal place of business in the state, maintains investment discretion or is deemed to have custody of client assets.

These annual submissions (outside of the IARD/CRD system) of the financial statement and/or other documents to a home state securities regulator are oftendue within 90 days of the end of an investment adviser’s fiscal or calendar year end, however, some state securities regulators utilize a different schedule such as the deadline in December for payment of the Preliminary Renewal Statement.

RIA Compliance Consultants, Inc. recommends that if your firm is state registered, you immediately review any communication that you received recently from your state securities regulator on this subject or contact your home state securities regulator to confirm whether there are any annual submissions (outside of the IARD/CRD system) such as an annual financial statement due for your state registered investment adviser firm.

Related Resources

Understanding Nebraska’s Annual Reporting Requirements for State-Registered Investment Advisers (11/14/2023)

Don’t Stop at Form ADV Annual Amendment – Certain States Require Annual Financial Statement (2/7/2023)

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 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.