Now that we are into a new year, can you confirm your registered investment adviser firm and its investment adviser representatives were properly renewed for 2015? Every year there are always a handful of investment adviser firms that fail to submit renewal fees through the IARD system in a timely fashion. Therefore, even if you think the renewal payment was sent in time, please make sure your investment adviser firm retrieves the Final Renewal Statement and confirms it is renewed for calendar year 2015.
Category Archives: IARD
Preparing Your Form ADV Annual Amendment
January 03, 2015
Your investment adviser firm’s Final Renewal Statement and report are now available for viewing and printing.
Preliminary Renewal Statements Now Available
November 21, 2013
As of Monday, November 11, 2013, your investment adviser firm can access its Preliminary Renewal Statement for the upcoming year via its IARD account. Investment adviser firms are assessed individual registration fees based on the state(s) that the firm is notice filed or registered in and the number of investment adviser representatives and their approved registration statuses. The amount reflected in the Preliminary Renewal Statement is the amount of renewal fees investment advisers must pay in order to maintain active registration for the firm and its investment adviser representatives.
Failure to Properly Renew Registration may Result in Adverse Consequences for Investment Advisers
October 22, 2013
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 on December 31 of each calendar year. In order to ensure investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2014, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.
Annual Renewals of Investment Adviser is Quickly Approaching
October 16, 2013
As 2013 is quickly coming to an end, 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 deminimus 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.
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.
As we previously indicated in an article on June 28, 2013, Minnesota will soon begin requiring registration for investment adviser representatives located or conducting business in Minnesota. In order to register investment adviser representatives, investment advisers will have to file a Form U4 through Web CRD/IARD system. Investment adviser representatives will be required to meet the examination requirements defined in the law, the Series 65 examination or the Series 7 and Series 66 examinations, prior to being registered. The new law was effective August 1, 2013.
The Minnesota Department of Commerce – Securities Unit recently announced that during the last legislative session a bill was passed that has now been signed into law, resulting in changes to investment adviser representative (“IAR”) registration requirements. One of the significant changes that will likely impact many federally and state registered investment advisers, located or conducting business in Minnesota, is the requirement to register investment adviser representatives through the Web CRD/IARD system. Prior to this recent legislation, Minnesota did not have registration requirements for investment adviser representatives. However, Minnesota Statute 80A.58 Section 403(a) has now been revised to state, “It is unlawful for a person to transact business in this state as an investment adviser or investment adviser representative unless the person is registered under this chapter or is exempt from registration. . . .”
IARD Replacing System for a Registered Investment Advisor to Fund IARD/CRD Daily Account
April 19, 2013
Effective March 18, 2013, the IARD/CRD system implemented an E-Bill system for registered investment advisor firms to fund their FINRA Flex-Funding Account (CRD/IARD Daily Account). See the Account Payment Methods and Addresses section in the IARD public site for detailed information. Investment advisor firms may continue to use the existing Web CRD/IARD E-Pay system to make electronic (ACH) payments to their Daily Account until June 17, 2013, when the Web CRD/IARD E-Pay link will be replaced by a link to E-Bill.
How Much Will It Cost to Register an Investment Adviser?
February 10, 2013
When an individual is considering whether to start a registered investment adviser, a primary concern is how much will it cost to set-up an investment adviser firm. The set-up expenses can vary greatly depending upon whether the firm will need to register as an investment adviser with the U.S. Securities Exchange Commission (“SEC”) or with the state securities regulator, the size of the investment adviser, the complexity of the proposed investment adviser’s business model, and the conflict or potential conflict of interest situations that will exist. An individual looking to register as an investment adviser will not only need to take into consideration the cost involved in the actual investment adviser registration process but will also need to consider the cost of getting the appropriate office set-up and systems in place as well as any staffing related costs.
