On November 8th, 2021, the preliminary renewal statement for every registered investment adviser (“RIA”) firm will be posted on the Investment Adviser Registration Depository (“IARD”) website. Renewal statements are only available online via the IARD website. Statements are not physically mailed to firms. If an RIA firm was first registered in 2021, the firm is still required to pay the proper renewal fees. A firm’s registration will be terminated if they fail to pay renewal fees to the proper jurisdiction(s).
The deadline to pay renewal fees for this year’s renewal season is Monday, December 13, 2021. Firms must have paid all mandatory preliminary renewal fees by this date. All RIA firms are strongly encouraged to submit all renewal payments by Thursday, December 9, 2021 to ensure proper payment processing time.
Every investment advisory firm’s final renewal statement will be posted on the FINRA Gateway on Saturday, January 2, 2022. The final renewal statement will account for any charges to the firm or individual investment advisers’ registration which occurred after the posting of the RIA firm’s preliminary renewal statement. The deadline to pay the final renewal fees is Friday, January 28, 2021. All RIA firms are strongly encouraged to submit final renewal payments by Wednesday, January 26, 2022 to ensure proper payment processing time.
RIA firms registered with the SEC will also need to pay the SEC Annual Updating Amendment Fee before filing the required Form ADV amendment. Traditionally, the SEC amendment fee for RIA firms with over $100 million in assets under management (“AUM”) is $225. For SEC-registered firms with between $25-$100 million in AUM, the fee is $150, and for SEC-registered firms with less than $25 million in AUM, the fee is $40. As a reminder, these SEC annual amendment fees are charged in addition to the annual notice-filing and individual investment adviser representative registration fees charged by the relevant states to firms registered at the federal level.
All RIA firms, whether registered at the SEC or state level, will also need to file the required Form ADV amendment within 90 days of the firm’s fiscal year-end (generally March 31, 2022 with a traditional December 31, 2021 fiscal year end date). In addition, SEC-registered firms may need to file an amendment to their firm’s Form ADV part 3 (Form CRS). While submitting an annual amendment to the Form CRS may not be required, it may be necessary if material changes have been made.