Your RIA firm’s preliminary renewal statement was posted on the IARD web site in early November. Failure to pay your investment advisory firm’s renewal fees to the proper jurisdictions will result in the termination of the firm’s registration. Even if your RIA firm was first registered in 2013, you are still required to pay the proper renewal fees.
The deadline to pay the preliminary renewal fees is Friday, December 13. However, it is strongly recommended that all payments be submitted by Tuesday, December 10 as it does take a few days for the system to process the payments.
Your investment advisory firm’s final renewal statement will be posted on the IARD system on Thursday, January 2, 2014. The final renewal statement will account for any changes to your firm or individual investment advisers’ registration which occurred after the posting of your RIA firm’s preliminary renewal statement. The deadline to pay the final renewal fees is Friday, January 10. Once again, all RIA firms are strongly encouraged to submit all renewal payments by Tuesday, January 7 to ensure proper payment processing time.
RIA firms registered with the SEC will also need to pay the SEC Annual Updating Amendment Fee before being able to file the required Form ADV amendment. 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 the annual notice-filing and individual investment adviser registration fees which are charged to the SEC-registered RIA firms by the relevant states.
All registered investment advisory firms, whether registered at the SEC or state level, will need to file the required Form ADV amendment within 90 days of the firm’s fiscal year-end (generally March 31, 2014). Check back soon for more information on the annual Form ADV amendment.