On November 16, 2020, the preliminary renewal statement for every registered investment adviser ("RIA") firm will be posted on the Investment Adviser Registration Depository ("IARD") website. Renewal statements are only available online via the IARD website; they are not physically mailed to firms. If an RIA firm was registered in 2020, the firm is still required to pay the proper renewal fees. A firm’s registration will be terminated if they fail to pay renewal fees to the proper jurisdiction(s).
The deadline for this year's renewal season is Monday, December 14, 2020. Firms must have a receipt of mandatory preliminary renewal fees by this date. All RIA firms are strongly encouraged to submit all renewal payments by Wednesday, December 9, 2020 to ensure proper payment processing time.
Every investment advisory firm’s final renewal statement will be posted on the IARD system on Saturday, January 2, 2021. 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 22, 2021. All RIA firms are strongly encouraged to submit final renewal payments by Wednesday, January 20, 2021 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, 2021 with a traditional December 31, 2020 fiscal year end date). In addition, SEC-registered firms may need to file an amendment to their firm's Form ADV part 3 (Form CRS). While submitting an annual amendment to the Form CRS may not be required, it may be necessary if material changes have been made.