Starting Monday, November 11, 2013, a registered investment adviser firm can access its 2014 Preliminary Renewal Statement via its IARD account. The Preliminary Renewal Statement must be paid, in full, by Friday, December 13, 2013. Since it takes approximately two days for payment to post to the IARD account, your firm’s payment should arrive at FINRA no later than Wednesday, December 11, 2013, to ensure that funds are posted to your firm’s IARD account by December 13, 2013.
Category Archives: Annual Amendment
Investment Advisers Should Begin Preparations for 2014 Renewals
October 09, 2013
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 should be reviewed and monitored on an ongoing basis, the annual renewal process should be used as a time to confirm that the investment adviser is properly registered or notice filed (as applicable) and that its representatives are properly licensed. 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.
Note to SEC Registered Investment Advisers Concerning Form ADV Annual Updating Amendments
February 06, 2013
On February 06, 2013, the U.S. Securities and Exchange Commission (“SEC”) released an important notice concerning Form ADV Annual Updating Amendment for December fiscal year end advisers. According to the notice, those investment advisers registered with the SEC with a fiscal year end of December 31, 2012, are required to file their annual updating amendment within 90 days after their fiscal year end, thus, by March 31, 2013. As March 31, 2013, falls on a Sunday and because the IARD system will be closed on Friday, March 29, 2013, investment advisers with a December 31, 2012, fiscal year end will be allowed to file their annual updating amendments no later than Monday, April 1, 2013. The SEC adds: “Rule 0-4 under the [Investment Advisers Act of 1940] provides that fillings (sic) required to be made through the IARD system on a day that the IARD system is closed will be considered timely filed with the commission if filed through the IARD system no later than the following business day. (see Title 17: Commodity and Securities Exchanges Part 275 – Rule and Regulations, Investment Advisers Act of 1940.)”
Calculating an Investment Adviser’s Regulatory Assets Under Management When Preparing the Form ADV Annual Amendment
January 08, 2013
Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with the state securities regulators must file a Form ADV Annual Amendment each year within 90-days of the investment adviser’s fiscal year end. Many registered investment advisers have a fiscal year end of December, which means that the Form ADV Annual Amendment for fiscal year end 2012 must be filed sometime between now and March 30, 2013.
Registered Investment Advisers Form ADV Annual Amendments
December 27, 2012
An investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) is required to file an amendment to the investment adviser’s Form ADV at least annually within 90-days of the investment adviser’s fiscal year end. Most state securities regulators have similar rules requiring the Form ADV annual amendment filing. Many registered investment advisers have a fiscal year end of December 31, which means that a Form ADV annual amendment will need to be filed through the IARD system no later than March 30, 2013, in order to comply with SEC and state securities regulators’ requirements. Failure to amend an investment adviser’s Form ADV is a violation of SEC and similar state securities regulations and could lead to an investment adviser’s registration being revoked.
State Registered Investment Advisers Need to be Aware of Newly Released Revisions to Part 1B of Form ADV
December 19, 2012
On October 29, 2012, the North American Securities Administrators Associations (“NASAA”) approved revisions to Part 1B of the Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers (“Form ADV”). Investment advisers registering with one or more state securities regulators are required to complete Form ADV Part 1B. Additionally, state-registered investment advisers making an annual updating amendment or an other-than-annual amendment to an existing registration will be required to use the revised Form ADV Part 1B. According to NASSA, “As the majority of state-registered investment advisers have a December 31, 2012 fiscal year-end, and therefore are required to make their annual updating amendment filings by March 30, 2013, in accordance with the instructions in Form ADV, we expect that the majority of state-registered investment advisers will be filing the revised Form ADV Part 1B in the first quarter of 2013.”
Registered Investment Advisors Must File a Form ADV Amendment Annually
December 11, 2012
According to Rule 204-1 of the Investment Advisers Act of 1940, all investment advisors registered with the U.S. Securities and Exchange Commission (“SEC”) must file an amendment to the investment advisor’s Form ADV at least annually within 90-days of the investment advisor’s fiscal year end. Most state securities regulators have similar rules requiring the annual Form ADV filing. For many registered investment advisors December 31 is their fiscal year end, which means that a Form ADV annual amendment will need to be filed through the IARD system no later than March 29, 2013 in order to comply with SEC and state securities regulator requirements.
Form ADV Annual Updating Amendments
November 28, 2012
As the IARD renewal process begins to wrap up, most registered investment advisors should also be preparing for the filing of the annual Form ADV updating amendment. Investment advisors registered with the U.S. Securities and Exchange Commission (“SEC”) and state registered advisors must file a Form ADV Annual Amendment within 90 days of the investment advisor’s fiscal year.
Investment Advisers Should Begin Preparations for 2013 Renewals
October 02, 2012
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.
Final Renewal Statements Now Available in the IARD/Web CRD System
January 10, 2012
Final Renewal Statements for registered investment advisors are now available in the IARD/Web CRD system. These statements will reflect the final registration statuses of the investment advisor firm and its representatives as of December 31, 2011. Final Renewal Statements will reflect that the investment advisor is “Paid In Full,” has an “Amount Due,” or “Failed to Renew.”
