As we roll into the holiday season and prepare for year end, there is yet another certainty. If your fees are not paid in December, you won't be a Registered Investment Advisor in 2015!
FINRA Preliminary Renewal Statements
While FINRA is not your RIA's regulator, they do own the systems that the SEC and the States use to register your firm and its advisory persons. They are also paid to administer the task of collecting your money for the regulators. Starting on November 10, 2014, FINRA will begin emailing designated contacts in your firm with your Preliminary Renewal Statement. This statement identifies what you owe based on where you are registered at the firm and individual levels. All payments must then be made prior to December 12, 2014.What other steps should my firm take?
- Review client geography and registration requirements. Are both your RIA firm and your investment advisor representatives properly notice filed and/or registered with each state in which you conduct business (or exempt)? If you exceed the de minimis threshold, you may be required to notice file or register.
- Review existing registrations. Are you registered in any states where you are under de minimis standards?
- Review IAR Registrations. Are your IARs properly registered? For SEC firms, some states do not require IAR registration if there is no place of business or under the de minimis threshold.
What happens if I don't pay my fees?
On December 31, 2014, all RIA and IAR registrations expire. If you have not paid and renewed those registrations for 2015, you may be terminated and your right to do business may be revoked. Several states automatically terminate your registration through their participation in the Automatic Fail To Renew Program for 2015. If your RIA firm or its representatives are registered or notice filed in a jurisdiction that participates in the program, your jurisdiction has authorized FINRA to automatically terminate your registrations on December 31, 2014 if all fees are not correct funded in the IARD Renewal Account by the deadline (December 12, 2014).
If you are an AdvisorAssist Compliance Client, we will analyze your account and your Preliminary Renewal Statement to provide guidance on requirements and fees. You may also receive notices from the state(s) and/or FINRA. You may forward those to our attention.
If you are not an AdvisorAssist Compliance Client, we welcome the opportunity to discuss our services. Please contact us at email@example.com.
Additional information can be found on the FINRA website.