Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 14, 2020

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As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 14, 2020 in order to cover such fees (with a recommendation from IARD to initiate any funds transfer no later than December 9, 2020 in order to allow 2 to 3 business days for processing).  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)
  • SEC-registered advisers that are required to make notice filings with one or more states
  • 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 14th.  An adviser who fails to fund the account by this deadline will have to discontinue its investment advisory business after December 31, 2020.  Annual amendments to Form ADV are due within 90 days of an adviser’s fiscal year end, or by March 31, 2021 for advisers with a December 31 fiscal year end.

Federal filing 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.

Additional information about obtaining your renewal statement and funding your account is available at https://www.iard.com/renewal-program.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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