As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 12 in order to cover such fees. This deadline applies to the following advisers and representatives:
- State-registered investment advisers
- State-exempt reporting advisers (including those that are also SEC-exempt reporting advisers)
- Notice filers (i.e., SEC-registered advisers that are required to make a notice filing with a particular state)
- All investment adviser representatives
Fees must be paid through the IARD website and should be deposited into the renewal account. Funds must be posted to advisers' renewal accounts by December 12. An adviser who fails to fund the account by this deadline will have to discontinue its investment advisory business after December 31, 2014. Annual amendments to Form ADV are due within 90 days of an adviser's fiscal year end, or by March 31, 2015 for advisers with a December 31 fiscal year end.
Fees for SEC-registered advisers and SEC-exempt reporting advisers are collected separately in connection with the annual update to the Form ADV that must be filed by such advisers.
Annual amendments to Form ADV are due within 90 days of an adviser's fiscal year end, or by March 31, 2015 for advisers with a December 31 fiscal year end.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.