On November 11, 2019, the preliminary renewal statement for every registered investment adviser ("RIA") firm will be posted on the Investment Adviser Registration Depository ("IARD") website. A firm’s failure to pay renewal fees to the proper jurisdiction(s) will result in the termination of the firm’s registration. It's also important to note that renewal statements are not physically mailed to firms as statements are only available online via the IARD website. Even if an RIA firm was first registered in 2019, the investment advisory firm is still required to pay the proper renewal fees this year.
For this year's renewal season, the deadline for receipt of mandatory preliminary renewal fees is Monday, December 16, 2019. All RIA firms are strongly encouraged to submit all renewal payments by Wednesday, December 11, 2019 to ensure proper payment processing time.
Every investment advisory firm’s final renewal statement will be posted on the IARD system on Thursday, January 2, 2020. The final renewal statement will account for any charges to the firm or individual investment advisers’ registration which occurred after the posting of the RIA firm’s preliminary renewal statement. The deadline to pay the final renewal fees is Friday, January 17, 2020. All RIA firms are strongly encouraged to submit final renewal payments by Wednesday, January 15, 2020 to ensure proper payment processing time.
RIA firms registered with the SEC will also need to pay the SEC Annual Updating Amendment Fee before being able to file the required Form ADV amendment. Traditionally, the SEC amendment fee for RIA firms with over $100 million in assets under management ("AUM") is $225. For SEC-registered firms with between $25-$100 million in AUM, the fee is $150 and for SEC-registered firms with less than $25 million in AUM, the fee is $40. As a reminder, these SEC annual amendment fees are charged in addition to the annual notice-filing and individual investment adviser representative registration fees which are charged by the relevant states to firms registered at the federal level.
All RIA firms, whether registered at the SEC or state level, will also need to file the required Form ADV amendment within 90 days of the firm’s fiscal year-end (generally March 30, 2020 with a traditional December 31, 2019 fiscal year end date). In addition, many SEC-registered firms will need to file their initial Form CRS beginning on May 1, 2020 and no later than June 30, 2020.