As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 18 in order to cover such fees. This deadline applies to the following advisers and representatives:
- State-registered investment advisers
- State-exempt reporting advisers (including those that are also SEC-exempt reporting advisers)
- Notice filers (i.e., SEC-registered advisers that are required to make a notice filing with a particular state)
- All registered investment adviser representatives
Fees must be paid through the IARD website and should be deposited into the renewal account. Funds must be posted to advisers' renewal accounts by December 18. If an adviser maintained a sufficient balance in its flex-funding account as of December 11 to pay its applicable state renewal fees, the amount of those renewal fees will be automatically transferred to the adviser's renewal account. An adviser who fails to fund the renewal account by this deadline will have to discontinue its investment advisory business after December 31, 2015. Annual amendments to Form ADV are due within 90 days of an adviser's fiscal year end, or by March 30, 2016 for advisers with a December 31 fiscal year end.
Fees for SEC-registered advisers and SEC-exempt reporting advisers are collected separately in connection with the annual update to the Form ADV that must be filed by such advisers.
Additional information about obtaining your renewal statement and funding your account is available here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.