Preliminary Renewal Statement Now Available

November 12, 2024

As of Monday, November 11, 2024, your investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for the upcoming year. 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 advisors must pay in order to maintain active registration for the firm and its investment adviser representatives.

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Preliminary Renewal Statements Available Monday

November 08, 2024

Starting Monday, November 11, 2024, a registered investment adviser firm can access, via its IARD account, its Preliminary Renewal Statement for 2025 renewals. The Preliminary Renewal Statement must be paid, in full, by Monday, December 9, 2024. 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 4, 2024, to ensure that funds are posted to your firm’s IARD account by December 9, 2024.

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New AML Requirements for Investment Advisers

October 04, 2024

Overview of FinCEN’s New AML Rule

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has finalized new anti-money laundering (AML) and countering the financing of terrorism (CFT) regulations applicable to certain investment adviser firms. The rule expands the scope of the Bank Secrecy Act (BSA) to include investment advisers registered with the U.S. Securities and Exchange Commission (SEC) and exempt reporting advisers (ERAs). This significant regulatory development is designed to protect the U.S. financial system from being used by criminals for illicit finance activities, including money laundering and terrorist financing.

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SEC’s Recent Enforcement Actions Against Investment Advisers For Failing to File Form 13F

September 29, 2024

The U.S. Securities and Exchange Commission (“SEC”) recently settled charges against 11 institutional investment managers for failing to file Form 13F, a critical filing requirement for those who exercise investment discretion over $100 million or more in certain equity securities. The SEC emphasized the importance of compliance with Form 13F, which ensures transparency in securities holdings and fosters market integrity.

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Regulatory Alert: New Form N-PX Reporting Requirements for Investment Advisers Which Are 13F Filers

August 12, 2024

If your investment adviser firm is required to file Form 13F, please be aware that your firm is now required (subject to certain exceptions) by the United States Securities and Exchange Commission (“SEC”) to file an annual report on Form N-PX by August 31, 2024. This report will cover the most recent 12-month period ending June 30 and must include the firm’s proxy voting record related to executive compensation matters.

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Regulatory Alert – SEC Amends Reg S-P

May 28, 2024

The U.S. Securities and Exchange Commission (SEC) has adopted amendments to Regulation S-P which require investment adviser firms registered with the SEC to adopt written policies and procedures for incident response programs to address unauthorized access to or use of customer information including procedures for providing timely notification to customers affected by an incident involving sensitive customer information.

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2024 SAA Certification Entitlement

April 12, 2024

The FINRA 2024 Entitlement Certification period will begin on Monday, April 15. This is when FINRA begins requiring all Super Account Administrators (“SAA”) to certify the other administrators and users with accounts on the IARD/Web CRD system. The SAA for your investment adviser firm has the ability to create/delete other administrators and user accounts. An administrator can create/delete user accounts. For more information about the importance and responsibilities of the SAA, see the following website: https://www.finra.org/filing-reporting/entitlement/super-account-administrator-saa

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