Starting Monday, November 8, 2021, a registered investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for 2022 renewals. The Preliminary Renewal Statement must be paid, in full, by Monday, December 13, 2021. 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 8, 2021, to ensure that funds are posted to your firm’s IARD account by December 13, 2021.
Failure to maintain active registration or failure to properly renew registration by the deadline may be detrimental to an investment adviser firm. Investment adviser firms and investment adviser representatives that are not properly renewed may become ineligible to conduct business effective January 1, 2022. Additionally, certain regulators may assess fines against those firms or representatives that fail to properly renew.
Most jurisdictions participate in the IARD Automatic Failure to Renew Program. If your investment adviser firm or its representatives are registered or notice filed in a jurisdiction that participates in the IARD Automatic Failure to Renew Program, your jurisdiction has authorized FINRA to automatically terminate your investment adviser firm and investment adviser representative registrations on December 31, 2021, if your investment adviser firm’s IARD Renewal Account is not funded by the renewal deadline.
Unfortunately, every year there are investment adviser firms that fail to submit renewal fees through their IARD accounts in a timely fashion, and almost all state securities regulators will automatically terminate these registered investment adviser firms and their investment adviser representatives for failing to pay their renewal fees. Contacting each state securities regulator after such a failure to renew can be time intensive and potentially expensive since a state securities regulator typically has the authority to require a new registration application and prohibit the charging of investment advisory fees as long as the investment adviser and its representatives are unregistered.
To help avoid problems with your investment adviser’s annual renewals, RIA Compliance Consultants recommends that you utilize our IARD Renewal Program and ADV Annual Amendment Service. For only $1,095*, investment advisers that engage us by executing the engagement and remitting the retainer fee prior to November 30, 2021, will receive assistance with the annual renewal process and with preparing and submitting the Form ADV Part 1 Annual Amendment that all investment advisers are required to file and submit within 90 days following the investment adviser’s fiscal year. Engagement of RCC after November 30, 2021 will be subject to availability and additional fees will be charged.
If you would like to engage RIA Compliance Consultants to assist you with your annual renewals and Form ADV annual amendment, please click here to purchase the service online and execute the letter of engagement. If you would like to discuss these services, contact your support person or our business development team at bizdevteam@ria-compliance-consultants.com.
*NOTE: Firms managing private funds may be charged additional fees. If you manage one or more private funds, please contact us to discuss the fee prior to engaging RIA Compliance Consultants for the 2022 IARD Renewal and Form ADV Annual Amendment package.
Related Resources
- 2022 IARD Renewal and Form ADV Annual Amendment Service
- Nebraska State-Registered Investment Adviser Renewal Requirements for 2022 – November 1, 2021
- Failure to Properly Renew Registration May Result in Adverse Consequences for Investment Advisers – October 29, 2021
- FAQ – An Investment Adviser’s IARD Renewals
- FAQ – Form ADV Drafting Tips
General Disclosure
The information contained in this blog post is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic. It is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. For more information, please see our Disclosures webpage.
Posted by RCC
Labels: ADV Annual Offer Letter, IARD, Renewals
