Registered investment adviser (RIA) registration renewal season is right around the corner. Nov. 8 marks the beginning of RIA renewal season for firms registered with the Securities and Exchange Commission (SEC), yet it is by no means the only critical date firms should mark on their calendars. In this blog, we’ll recap the requirements to register your firm with the SEC and dive into upcoming deadlines for those firms going through the RIA annual renewal season this year ─ including when you can expect your preliminary renewal statement to be posted to the IARD website.
For firms just starting out, you may be asking, what forms and filings are required to begin the registration process? And for established firms, you may be looking for a review of the process prior to renewal season kick off.
So, what exactly is involved? And what can you expect if it’s your first year renewing your RIA? Let’s dig in.
RIA state vs SEC registration - How to register as an RIA for the first time
First things first, if you are registering your firm with the SEC, there are certain requirements which must be fulfilled to start the process, including:
- FINRA Entitlement paperwork.
- Form ADV 1 (online).
- Form ADV 2A (paper and online).
- Form ADV 2B (paper and online).
- Client advisory contract and regulatory paperwork.
- Policies and procedures manual.
- Code of Ethics.
* It should be noted, however, that states may require additional or differing forms to register your firm.
In addition to filing the appropriate forms, firms first starting out should choose a chief compliance officer (CCO), invest in cybersecurity protection, select the right insurance (including errors and omission insurance and cybersecurity insurance) and ensure you have a full understanding of the fiduciary duty required for RIAs.
IARD preliminary renewal statement posting date and other important deadlines for RIA renewal season
For those firms renewing their RIA registration this year, the process, while less tedious, is just as critical to maintaining your standing with the SEC.
Beginning on Nov. 7, your firm’s preliminary renewal statement will be posted to the Investment Adviser Registration Depository (IARD) website, after which, firms will be expected to abide by the following renewal deadlines:
- Dec. 12: Renewal season payment.
- Jan. 27: Final renewal fee payment.
- Mar. 31: Submission of Form ADV amendment.
Additionally, firms registered with the SEC will be required to pay the SEC Annual Updating Amendment Fee.
RIA in a Box LLC is not a law firm, investment advisory firm, or CPA firm. RIA in a Box LLC does not provide legal advice or opinions to any party or client. You should always consult your relevant regulatory authorities or legal counsel if applicable.