If your firm is registered as an investment adviser (IA) then you may have received notice from FINRA to renew your firm’s registration for 2013. If you have not received the notice or have not paid the renewal fees, the following provides an overview of the process.
IA firms and IA representatives (RAs) should be aware that registrations expire annually on December 31. In order for an IA firm to maintain their active registrations and/or notice filing statuses and for RAs to maintain active registration statuses, the IA firms must pay applicable renewal fees annually. The IARD Renewal Program facilitates the annual renewal process. A Preliminary Renewal Statement which is made available on the IARD system, will include an amount that must be paid to FINRA by December 13, 2012. Remember to allow sufficient
time for payments made by check and sent through the postal service. Online payments made via E-Pay should be made by December 10, 2012 in order for the funds to be posted by December 13, 2012.
The preliminary renewal statement have been made available. IA firms can access this statement via IARD by following these steps:
1. Log onto IARD here.
2. Enter your firm’s ID and password.
3. Review and accept the terms and conditions.
4. Under the “Accounting” tab at the top of the page, select “Renewal Account.”
5. One the left column, select “Renewal Statement.”
The bottom of the page provides an itemized list of all applicable fees.
Payment by Check
If you choose to submit payment by check, print the statement and mail it, along with the check to the following address:
P.O. Box 7777-9995
Philadelphia, PA 19175-0001
(Note: this P.O. Box address will not accept courier or overnight deliveries.)
500 Ross Street 154-0455
Pittsburgh, PA 15262
The check should be made payable to: FINRA. Be sure to write your CRD Number and the word “Renewal” on the face of the check. Be sure to also include the first page of the Renewal Statement.
Payment via CRD/IARD E-Pay
Payment can also be submitted online via CRD/IARD E-Pay. To do so, follow these instructions:
Go to the E-Pay website and:
1. Enter your login and password. If you have not yet created an account, do so by clicking “sign up.”
2. On the left column under “Payments,” click “Pay my accounts.”
3. Select the account and click “Continue.”
4. Enter the total Payment Amount and check “Renewal” under Account Type. Then enter the payment method and click “continue.”
5. Review the information and click “Make Payment.”
6. Log out and the money should post within about 2 days.
Automatic Daily Account-to-Renewal Account Transfer
If your firms has sufficient funds in the Daily Account to cover the total renewal amount, FINRA will automatically process the renewal payment by the payment deadline.
Other Payment Methods
Wire payments sent by 2 p.m. (ET), should post the next business day. Wire payments sent after 2 p.m., ET, may take up to 2 business days to post. Instructions for initiating a wire can be found here.
After payment is submitted, you will be able to retrieve your firm’s online Final Renewal Statement on IARD on or after January 2, 2013. These statements will reflect the final registration status of the IA firm and RAs. To do so, follow the instructions above to log onto IARD. Under the “Renewal Statement” link in the “Accounting” section, you can retrieve the Final Renewal Statement, which will state “Paid in Full” or “Amount Due.” If an amount is due, the balance must be paid by February 1, 2013.
It is important to make sure payment is made by the deadline, otherwise the registration may be terminated. The firm will then have to contact each regulator to request re-registration instructions.
More information about the Renewal Program can be found on the IARD website. FINRA has also posted a bulletin on the 2013 IARD Renewal Program, available here.
Cole-Frieman & Mallon LLP provides legal services to hedge fund managers and investment advisers. Bart Mallon can be reached directly at 415-868-5345.