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.
Category Archives: Renewals
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.
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.
Registered Investment Adviser’s Preliminary Renewal Statement Now Includes a New Line Item Fee for Each IAR
November 16, 2012
For any individual responsible for reviewing and interpreting his or her registered investment adviser firm’s Preliminary Renewal State, there’s a new line item charge worth noting. In past years, the IARD system waived the RA system processing fee for each investment adviser representative’s electronic filing activity; however, for this year, an investment adviser firm’s renewal fees apparently include a $10.00 annual fee per investment adviser representative, which is described as “RA System Processing Fee” on an investment adviser firm’s Preliminary Renewal Statement. For more details from the IARD system, please click here.
Incorrect Fee on Preliminary Renewal Statement for Georgia Investment Adviser Representatives
November 16, 2012
The Georgia Securities Division recently issued a notice for investment adviser representatives registered in Georgia. The notice indicated that due to an administrative error, an investment adviser firm’s Preliminary Renewal Statements, now available on the Web CRD / IARD system, does not accurately reflect the correct investment adviser representative renewal fee. The correct fee for individuals registered in Georgia as only an investment adviser representative is $100 per individual and not the $30 fee per individual as displayed on the Preliminary Renewal Statement. The Georgia Securities Division further indicated that correct fees will be displayed on Final Renewal Statements once those become available.
Renewals for Investment Advisers and Investment Adviser Representatives
November 02, 2012
Investment adviser firms and investment adviser representatives must maintain active registrations and/or notice filing statuses with applicable securities regulators. Investment advisers should be aware that renewing registrations and notice filing statuses includes paying all applicable renewal fees by December 13, 2012. Unless properly renewed, all investment adviser firm registration and notice filing statuses and all investment adviser representative registrations will expire on December 31st of each calendar year. Failure to maintain active registration or notice filing status or failing to properly renew registration or notice filing may be detrimental to an investment adviser. Investment adviser firms and investment adviser representatives that have not properly renewed their registrations or notice filing status with the appropriate securities regulators may become ineligible to conduct advisory business effective January 1, 2013. Additionally, certain securities regulators may assess fines against those investment advisers or investment adviser representatives that fail to properly renew.
Washington State Securities Division Releases Investment Adviser Renewal Notice for 2013
October 24, 2012
The Securities Division of the State of Washington’s Department of Financial Institutions released a memorandum regarding investment adviser renewals for 2013. Click here for more details about investment adviser and investment adviser representative renewals in State of Washington.
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.
2013 Renewal Program Calendar Now Available
September 13, 2012
The Investment Adviser Registration Depository (“IARD”) 2013 Renewal Program calendar is now available on the IARD website. Investment advisers are encouraged to access and utilize the 2013 renewal program calendar to ensure they do not miss important deadlines. It is imperative that investment advisers note some of the following key dates, including:
IARD Renewal Deadline Quickly Approaching & Information Regarding Annual Amendment
November 30, 2011
In order for an investment adviser to maintain active state registration or notice filing statuses, as well as active state registration statuses for investment adviser representatives licensed under an investment adviser firm, renewal fees must be paid, in full, by all investment advisers by no later than December 12, 2011. Investment advisers need to be sure to allow sufficient time for submitted funds to be processed and reflected in the renewal account; it is highly encouraged that investment advisers submit their renewal payments electronically by no later than December 8, 2011. If renewal fees are submitted by check via the U.S. postal service, the investment adviser must account for delivery and processing time. It is important to remember that failure to pay renewal fees in full and on time may result in the termination of your investment adviser firm and its investment representative’s active registration statuses. Additionally, many jurisdictions also impose fines against investment advisers that fail to renew properly.
