All registered investment advisers are required to annually renew their FINRA, other self-regulatory organization and state/jurisdiction registrations through the annual Renewal Program. This Renewal Program is not applicable to Exempt Reporting Advisers. The 2020 preliminary renewal statements were available on the IARD/CRD system on November 16, 2020. Preliminary renewal statements contain information regarding state registration and notice filing fees. Please note that renewal fees were required to be available in your IARD/CRD account by December 14, 2020. Final statements will be available on the IARD/CRD system on January 2, 2021 and will reconcile what was charged on the Preliminary Statement with what is actually owed January 1. If additional monies are owed, they have a final due date of January 22, 2021. Firms with sufficient monies in their Flex-Funding Account will have funds automatically transferred to their Renewal Account to cover total renewal fees owed. Once your renewal statement has been filed, your annual amendment to Form ADV will be due within 90 days after your fiscal year end.
Firms must successfully renew their registrations to ensure continued eligibility to do business effective January 2, 2021. This means submitting your renewal fees by the December 16 payment deadline. If payment is not received by FINRA on or before the deadline, the IARD system will automatically non-renew your firm on December 31, 2020.
FINRA's 2020 IARD Renewal Program site contains comprehensive information regarding renewal instructions, payment options and addresses, etc., and can be accessed by clicking the following link. https://www.iard.com/renewal-program
If we can be of any assistance with the above, or if you have any questions about this Alert, please contact Daniel G. Viola (Partner) at 212.573.8038, dviola@sadis.com or Eliott Frank (Partner) at 212.573.8148, efrank@sadis.com. In addition, for more information regarding our Regulatory Compliance practice, see our practice page for details.
