Investment Advisor and Investment Advisor Representative IARD System Fee Waiver

The SEC and NASAA have waived two separate charges for Investment Advisors for the 2009 calendar year.  The first charge being waived is a systems charge for the Investment Advisor to access the IARD system.  This fee used to be $30.  The second charge is the fee to access the IARD system for each investment advisor representative.  This fee used to be $30 as well, which went to the NASAA.  For small investment advisors this amounts to a small savings, however, larger firms with many investment advisor representatives will be pleased they will not have to pay this system fee.

However, fees which go to the individual states are not being waived and these fees are often in the range of $100-$500 for each investment advisory firm, and $30-$125 for each investment advisor representative depending on the state of registration.  For more information please see the press release below or contact your hedge fund attorney or compliance professional.  The full press release can be found here.

SEC, NASAA Announce IARD System Fee Waiver


Washington, D.C., Oct. 30, 2008 — The Securities and Exchange Commission and the North American Securities Administrators Association (NASAA) today announced they will waive the initial set-up and annual system fees paid by investment adviser firms to maintain the Investment Adviser Registration Depository (IARD) system. Separately, NASAA announced that for next year it will also waive those system fees paid by investment adviser representatives (IARs).

Andrew J. Donohue, Director of the SEC’s Division of Investment Management, said, “We are pleased to be able to continue the fee waiver of initial and annual fees paid by investment advisers through July 31, 2009. We are also pleased that enhancements will continue to be made to this important and useful online adviser registration and public disclosure system, which enables the investing public easily to access information about investment advisers.”

Fred J. Joseph, NASAA President and Colorado Securities Commissioner, said, “The IARD system promotes effective and efficient investor protection through readily accessible disclosure while offering a consistent and streamlined registration process for investment advisers and their representatives. Given the current economic climate, we are pleased that the IARD system’s ongoing success has allowed us to maintain the system fee waivers put in place in 2005 for investment adviser firms and also to fully waive for the first time the system fees paid by investment adviser representatives.”

For next year, NASAA will waive payment of initial and renewal IARD system fees by state-regulated investment adviser firms and investment adviser representatives’ initial and renewal fees. NASAA’s Board of Directors approved the system fee waiver and will continue to monitor the system’s revenues to determine whether future fee adjustments are warranted.

The IARD system is an Internet-based national database sponsored by NASAA and the SEC and operated by FINRA in its role as a vendor. IARD provides a single nationwide database for the collection and dissemination of information about individuals and firms in the investment advisory field and offers investment advisers and representatives a single source for filing state and federal registration and notice filings. The system contains the employment and disciplinary histories of more than 25,000 investment adviser firms and nearly 250,000 individual investment adviser representatives. IARD system fees are used for user and system support and for enhancements to the system.


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