Renewal season is officially upon us. And we’re here to help, with a highlight of the critical dates your firm needs to know in order to ensure proper 2023-2024 registration renewal.
To get started, on Nov. 6, 2023, 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 2023, 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).
Important dates for the 2023-2024 RIA firm registrational renewal season
The dates and information below was gathered from the FINRA and IARD websites.
- November 6
- Preliminary Statements are available through E-Bill and can be accessed through FINRA Gateway.
- December 6
- Recommended: Submit all electronic renewal payments by December 6, 2023, to ensure proper payment processing time.
- December 11
- Deadline: Receipt of Preliminary Statement payments.
- December 26
- Last day to submit form filings to CRD/IARD and Web EFT prior to year-end. Form filings must be submitted by 6 p.m. ET. CRD/IARD will be available from 5 a.m. to 6 p.m. ET.
- December 28 – December 31
- CRD/IARD are available for query purposes and to create “Pending” filings. FINRA Gateway is available.*
- January 1, 2024
- IARD/CRD are unavailable due to renewal processing. FINRA Gateway is available.*
- January 2, 2024
- Final Statements are available through E-Bill and can be accessed through FINRA Gateway.
- January 24, 2024
- Recommended: Submit all final electronic renewal payments January 24, 2024, to ensure proper payment processing time.
- January 26
- Deadline for receipt of Final Statement payment for all firms with balance due.
- March 17
- Recommended: All firms, whether registered at the SEC or state level also need to file the requisite Form ADV annual updating amendment within 90 days of the firm’s fiscal year-end. Firms with a traditional December 31 fiscal year end have a deadline of March 31, 2024.
- March 31
- Deadline: All firms with a December 31 fiscal year end must file the requisite Form ADV annual updating amendment.
As stated by FINRA, “Forms U4, U5 and BR are now available in FINRA Gateway, and filing capabilities for these forms have been retired in Classic CRD. While FINRA Gateway is usually available 24 hours a day, seven days a week, Forms U4, U5 and BR can only be submitted during Classic CRD hours of availability.”
Additional information for registration renewal season
RIA firms registered with the SEC will also need to pay the SEC Annual Updating Amendment Fee before filings can be submitted. Traditionally, the SEC amendment fee for RIA firms with more than $100 million in assets under management (AUM) is $225. For SEC-registered firms with $25 to $100 million in AUM, the fee is $150, and for SEC-registered firms with less than $25 million in AUM, the fee is $40.
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, 2024, with a traditional Dec. 31, 2023 fiscal year end date). In addition, 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.
Still have questions about the renewal process? Schedule time to speak with an expert today!