Category Archives: Annual Amendment
 

Deadline for Receipt of Preliminary Renewal Statement Payments Quickly Approaches

December 08, 2015

The deadline for investment advisers to submit their Preliminary Renewal Statement payment is quickly approaching. The Financial Industry Regulatory Authority (FINRA) must be in receipt of the full payment listed on the Preliminary Renewal Statement by Friday, December 18, 2015. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning on Friday, December 11, 2015 to their Renewal Account to cover total renewal fees owed. Automatic transfers will be conducted every day after December 11, 2015 until the WEB CRD/IARD shuts down for year-end processing on Tuesday, December 29, 2015. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline. If your investment adviser would like assistance with the annual renewal service, click here for more information on or to purchase RIA Compliance Consultants’ IARD Renewal Program and ADV Amendment Service. If you have questions regarding these or any of the other services offered by RIA Compliance Consultants, please contact your consultant if you are an existing client or click here if you have not previously engaged RIA Compliance Consultants for our services.

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Preliminary Renewal Statements Available Monday

November 12, 2015

Starting Monday, November 16, 2015, a registered investment adviser firm can access, via its Investment Adviser Registration Depository (IARD) account, its Preliminary Renewal Statement for 2016 renewals.  The Preliminary Renewal Statement must be paid, in full, by Friday, December 18, 2015.  Since it takes approximately two (2) days for a payment to post to the IARD account, your firm’s payment should arrive at the Financial Industry Regulatory Authority (FINRA) no later than Wednesday, December 16, 2015, to ensure that funds are posted to your firm’s IARD account by Friday, December 18, 2015.

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Investment Advisers Should Begin Preparations for 2016 Renewals

October 29, 2015

As annual renewal season rapidly approaches, investment advisers should be proactive and begin preparing for renewals by reviewing to make sure the investment advisor is properly registered or notice filed, as applicable, and that its investment adviser representatives are properly licensed with all required state securities regulators.  The IARD Renewal Program serves to facilitate the annual renewal of investment advisers and their investment adviser representatives’ registrations with the appropriate state securities regulators. Although, an investment adviser’s registration, notice filing, and licensing requirements is something that should be reviewed and monitored on an ongoing basis, during the annual renewal process all investment advisers should review their existing registration or notice filing status and each investment adviser representative’s licensing status to confirm that the investment adviser and its representatives are properly registered, notice filed, or licensed (as applicable).  Additionally, all state registered investment advisers should also review the state requirements to see if branch office registration is required and, if it is, investment advisers should confirm that all branch office locations have been properly registered.

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Form ADV Part 1 Annual Amendment

January 06, 2015

As an investment adviser, your firm is responsible for preparing and filing through the IARD system a Form ADV Part 1 Annual Amendment that must be submitted each year no later than 90 days after your investment adviser firm’s fiscal year end.

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Ensure Timely Preliminary Renewal Statement Payments

November 18, 2014

Don’t wait until the last minute to submit your annual renewal fees. FINRA must be in receipt of the full payment listed on the Preliminary Renewal Statement, which is now available, by December 12, 2014. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred on December 15, 2014 to the Renewal Account to cover total renewal fees owed. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline. If your investment adviser would like assistance with the annual renewal service, click here for more information on or to purchase RIA Compliance Consultants’ IARD Renewal Program and ADV Amendment Services.

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

October 21, 2014

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. In order to ensure that investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2015, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.

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Annual Renewals of Investment Adviser is Quickly Approaching

October 14, 2014

Now is the time for each registered investment adviser to begin preparations for IARD renewals for the investment adviser firm and its investment adviser representatives. Registered investment advisers must make sure that they remain properly registered at all times. If you are an SEC registered investment adviser, you must make sure that your investment adviser is notice filed in all required states. If you are a state registered investment adviser, you must make sure your investment adviser is properly registered in all required states.  Generally, registration or notice filing is required at the firm level if an investment adviser has a place of business in the state or if it exceeds the state’s de minimus exemption.  However, investment advisers must review each state’s notice filing or registration requirements prior to conducting business in a particular state.  Investment adviser representative licensing is always handled at the state level.  Investment adviser firms must review and determine that all investment adviser representatives are properly licensed prior to conducting business in a state.

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Investment Advisers Should Begin Preparations for 2015 Renewals

September 23, 2014

As annual renewal season rapidly approaches, investment advisers should be proactive and begin preparing for renewals by reviewing to make sure the investment adviser is properly registered or notice filed, as applicable, and that its investment adviser representatives are properly licensed with all required state securities regulators. The IARD Renewal Program serves to facilitate the annual renewal of investment advisers and their investment adviser representatives’ registrations with the appropriate state securities regulators. Although, an investment adviser’s registration, notice filing, and licensing requirements is something that should be reviewed and monitored on an ongoing basis, during the annual renewal process all investment advisers should review their existing registration or notice filing status and each investment adviser representative’s licensing status to confirm that the investment adviser and its representatives are properly registered, notice filed, or licensed (as applicable). Additionally, all state registered investment advisers should also review the state requirements to see if branch office registration is required and, if it is, investment advisers should confirm that all branch office locations have been properly registered.

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Investment Advisers Should begin Preparing to Submit their Annual Form ADV Amendment

December 31, 2013

On Thursday, January 2, 2014, Final Renewal Statements and reports are available viewing and printing. Registered investment adviser firms should download and review these reports as soon as they become available; the deadline for receipt of Final Renewal Statement payments in January 10, 2014. Additionally, investment advisers firms with a fiscal year end of December 31 are encouraged to begin preparing their required Form ADV annual updating amendments. The Form ADV annual amendment must be submitted through the Web CRD / IARD system 90 days from an investment adviser’s fiscal year. An investment adviser needs to understand that failure to update the Form ADV, as required by the Form ADV General Instructions, is a violation of U.S. Securities and Exchange Commission (“SEC”) rules and similar state rules that could lead to an investment adviser’s registration being revoked. A registered investment adviser with a fiscal year end other than December must make sure to file its annual updating amendment within 90 days of the investment adviser firm’s fiscal year end.

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