San Diego, CA (PRWEB) November 14, 2012
Preliminary Renewal Statements are available on the Investment Adviser Registration Depository (“IARD”) and Central Registration Depository (“CRD”) systems beginning November 12. Firms must pay the entire amount reflected on the Preliminary Renewal Statement by December 13.
Business Compliance Partners recommends that each firm reviews a copy of their registered and non-registered person rosters. The rosters contain the names, addresses and licensing information (when applicable) of firm personnel. If anyone appears on the roster that no longer works for the firm, a Form U5 must be submitted to terminate that person’s registrations. Home and office addresses that are inaccurate should be updated as well as any other information that may have changed or be outdated. In addition, individuals may need to add or drop licenses or registrations.
The deadline for submitting form filings to drop registrations or licenses prior to year-end is December 21 at 6 p.m., Eastern Time (“ET”), via the CRD/IARD system. The IARD/CRD system will shut down in order to process registration and licensing information in order to generate Final Renewal Statements and will be unavailable for filings until January 2, 2013. Firms can create and submit postdated forms with December 31, 2012 as the effective date.
The easiest and most convenient way to pay renewal fees by the deadline is through the CRD/IARD E-Pay System. E-Pay enables a firm to authorize electronic payments directly from its designated bank account to its CRD/IARD Renewal Account. Electronic payments (ACH payments) submitted by 8 p.m., ET, should post within two business days. Firms are not charged any fees for using E-Pay; however, firms may be charged a separate fee by their banks.
Firms can also make deposits in their Renewal Accounts by check or wire transfer but may not pay fees using debit/credit cards or cash.
Any net increase in the number of licenses and registrations requested after Preliminary Renewal Statements are generated will result in additional charges and net decreases will result in refunds which will appear on Final Renewal Statements available beginning on January 2, 2013. Any amounts due must be paid by February 1, 2013.
The North American Securities Administrators Association (“NASAA’) has continued to waive IARD system fees for investment adviser firms but has reinstated the annual system fees paid by investment adviser representatives (“IARs”).
The IARD renewal fee will be $10 per IAR; making it lower than the original $45 fee when the IARD system first became operational. “Setting substantially reduced IARD fees for individual investment adviser representatives will allow us to ensure that the IARD system maintains a sufficient operating reserve without charging firms, many of which operate small businesses in local communities,” said Heath Abshure, NASAA President and Arkansas Securities Commissioner.
“By reinstating the system fees for IARs at a reduced level, we will be able to maintain a reserve for on-going operations and enhancements. We will continue our efforts to ensure that the system operates efficiently and NASAA’s Board of Directors will continue to monitor the system’s revenues and make future adjustments, including waiving the system fees as we have done in the past, if warranted,” said Abshure.
This process is less complicated than it sounds but firms should get started as early as possible in order to keep their businesses running smoothly in the New Year.