On Nov. 7, 2022, 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 2022, 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 fees for this year’s renewal season is Monday, Dec. 12, 2022. Firms must have paid all mandatory preliminary renewal fees by this date. RIA firms are strongly encouraged to submit renewal payments by Thursday, Dec. 8, 2022, to ensure proper payment processing time.
Every investment advisory firm’s final renewal statement will be posted on the FINRA Gateway on Monday, Jan. 2, 2023. 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, Jan. 27, 2023. All RIA firms are strongly encouraged to submit final renewal payments by Wednesday, Jan. 25, 2023, 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 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. 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, 2023, with a traditional Dec. 31, 2022 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.