Friday, December 30, 2011

2012 ADV Amendments

The SEC released an email today reminding Advisors that they must file an annual amendment for all applications with the SEC to validate your registration status.

AdvisorAssist will be assisting all registration and compliance clients with this process starting in the first week of January 2012.

This will be included as part of the annual renewal process for established advisors. For new firms, this will be addressed as part of the approval process. For more information on the SEC to State Transition, please see our prior blog post (SEC to State Transitions) on the requirements and Key dates.


Below is the text of the SEC Email:
SEC-Registered Adviser Form ADV Filing Requirements: January 1 - March 30, 2012
SEC-Registered Investment Advisers: Between January 1, 2012 and March 30, 2012, ALL SEC-registered advisers, and advisers who have an application for registration pending with the SEC, must file a Form ADV amendment (annual updating amendment or other-than-annual amendment), completing ALL items on the revised form (including corresponding sections of Schedules A, B, C and D) and indicating with which regulator they should be registered (in Item 2). Please note that ALL SEC-registered advisers must file a Form ADV amendment without regard to when their fiscal year ends (example: advisers with a June fiscal year end must file an other-than-annual amendment between January 1 and March 30, 2012). An adviser should also amend its brochure if any information has become materially inaccurate. Advisers seeking to file other-than-annual amendments to update only limited sections of Form ADV (for example: only the Part 2 brochure or their address in Item 1) must complete ALL questions, including new and revised questions, on Part 1 of the Form ADV. Advisers that must switch from SEC to state registration should mark Item 2.A.(13) and should begin registering with the state(s) to ensure they can withdraw their SEC registration by June 28, 2012. Please see the General Instructions to Form ADV http://www.sec.gov/about/forms/formadv-instructions.pdf and the SEC's recently adopted rules for more information (IA-3221 and IA-3222, June 22, 2011, on http://www.sec.gov/rules/final.shtml). You cannot reply to this email. If you have questions, please email IARDLIVE@SEC.GOV.
http://www.sec.gov/about/forms/formadv-instructions.pdf

Friday, December 9, 2011

Final Reminder - 2012 Renewal Fees Due 12/12/11!

This is a final reminder that full payment of your Preliminary Renewal Statement must post to your firm's IARD Renewal Account by December 12, 2011.

An investment adviser (IA) firm that does not pay its Preliminary Renewal Statement in full will have all of its representatives' (RAs) registrations with jurisdictions terminated effective December 31, 2011. Additionally, firms that fail to renew may be subject to fines levied by jurisdictions as well as re-registration requirements.

If you are an Ongoing Compliance Client of AdvisorAssist, you received an email from us with instructions. Otherwise, 
you can retrieve and print your statement by logging onto IARD and selecting the Renewal Statement link under the Accounting section of the site map. If you have not logged onto IARD in the last 120 days, your password has expired and you will need to select the Forgot Password? link on the left side of the login screen to have a new password emailed to you.


Detailed 
renewal payment options and instructions are available on the IARD websitePlease note: If you recently submitted your payment, check your firm's Renewal Account to ensure that the payment was received and processed.

For complete information, visit the 
2012 IARD Renewal Program Web page.



If you need assistance, please contact AdvisorAssist Support at Support@AdvisorAssist.com.

FINAL REMINDER: FINRA Entitlement User Accounts Certification Due 12/9/11

The 2011 FINRA Entitlement User Accounts Certification Period ended on 12/9/11. If your RIA did not certify its FINRA Entitlement User Accounts, the capability to utilize the IARD and CRD has been disabled for all Administrators and will remain disabled until your organization completes the certification process. 


To have full entitlement functionality restored, please complete the user account certification process by clicking here.


If you are an Ongoing Compliance Advantage client of AdvisorAssist, please contact us for support.