2024 SAA Certification Entitlement

April 12, 2024

The FINRA 2024 Entitlement Certification period will begin on Monday, April 15. This is when FINRA begins requiring all Super Account Administrators (“SAA”) to certify the other administrators and users with accounts on the IARD/Web CRD system. The SAA for your investment adviser firm has the ability to create/delete other administrators and user accounts. An administrator can create/delete user accounts. For more information about the importance and responsibilities of the SAA, see the following website: https://www.finra.org/filing-reporting/entitlement/super-account-administrator-saa

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Alert for Investment Advisers: Beware of Phishing Emails Impersonating FINRA

April 05, 2024

Beware of Phishing Emails Impersonating FINRA

On Thursday, April 4, we received numerous inquiries from investment adviser firm owners and/or senior executives who had received an unexpected email supposedly from FINRA’s Chief Legal Officer or Chief Information Officer which utilized an email address ending in @ data-finra .org. In response, our Consulting Team contacted the IARD Entitlement Support Line which confirmed that these emails did not originate from FINRA.

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Learn About the Exemption for Investment Advisers from New Beneficial Ownership Reporting Requirements

February 02, 2024

With the new requirements that corporations, limited liability companies and other entities report the identities of their beneficial owners to the Financial Crimes Enforcement Network (“FinCEN”), the chief compliance officer (“CCO”) of an investment adviser firm and sponsors of pooled investment vehicles should be aware that certain investment adviser firms and pooled investment vehicles are eligible for an exemption from FinCEN’s beneficial ownership reporting requirements.

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Lawsuit Filed Against Montana for Discriminatory Investment Adviser Representative Registration Fees

January 13, 2024

Litigation Alert

According to the Daily Montanan, a class-action lawsuit has been filed against the State of Montana. This lawsuit challenges the constitutionality of a licensing fee structure imposed on non-resident investment adviser representatives and securities salespersons, alleging it violates the privileges and immunities clause of the United States Constitution.

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Understanding Nebraska’s Annual Reporting Requirements for State-Registered Investment Advisers

November 14, 2023

For investment adviser firms which are state registered with Nebraska, it’s crucial to be aware that there are certain additional documents which must be submitted directly (via a ShareFile link) to the Nebraska Securities Bureau in addition to and separate from the paying the regulatory fees associated with annual renewals and filing the Form ADV Annual Amendment via the IARD (“Investment Adviser Registration Depository”) system.

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Navigating the Preliminary Renewal Statement for Investment Advisers

November 11, 2023

Understanding and Managing Your Firm’s Preliminary Renewal Statement

As we approach the end of the year, it is crucial for investment adviser firms to review their 2024 Preliminary Renewal Statements, which are now accessible through their IARD accounts. This statement is an overview of the firm’s current registration status and the associated renewal fees. Let us delve into the specifics of this renewal statement and its implications for your investment adviser firm.

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Failure to Properly Renew Registration May Result in Adverse Consequences for Investment Advisers

October 19, 2023

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 2024, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.

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