As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 11, 2023 in order to cover such fees (with a recommendation from IARD to initiate any funds transfer no later than December 7, 2023 in order to allow 2 business days for processing). 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)
- SEC-registered advisers that are required to make notice filings with one or more states
- All 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 11, 2023. An adviser who fails to fund the account by this deadline will have to discontinue its investment advisory business after December 31, 2023. If an adviser has sufficient funds to pay all renewal fees due within its IARD Flex-Funding Account, such amounts will be automatically transferred to its renewal account to pay the outstanding amount owed. Annual amendments to Form ADV are due within 90 days of an adviser's fiscal year end, or by March 30, 2024 (one day prior to the end of March due to the 2024 leap year) for advisers with a December 31 fiscal year end.
Federal filing 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 at https://www.iard.com/renewal-program.
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.
