IARD System Frequently Asked Questions - Form Filing for IA Firms
Joint IA/BD Firms

1. The Investment Adviser firm I work for is also a Broker-Dealer and, as such, the IA Firm is exempt from paying state Notice Filing fees in certain states. Since the firm is exempt from paying fees, does that mean I do not need to make a transition filing for those states in which our firm is exempt?

No. Simply being exempt from fees does NOT make your firm exempt from making a transition filing. If the state in question required your firm to submit a paper Notice Filing then you must make a transition filing on IARD regardless of your firm's fee exemption. The transition filing is necessary in order to reflect your firm's status as Notice Filed in those states and will not result in additional fees if your firm is qualified as fee exempt. If you are still uncertain as to whether or not you should transition file then please contact the state securities regulator directly. Their numbers are available on the NASAA Web Site.

2. My firm submitted the Form ADV with an initial DRP, but would now like to delete that DRP. Is that possible?

No. Once the filing has been submitted with the DRP, the DRP can only be updated and not deleted.

3.I am receiving a Completeness Check error regarding a linked DRP; however, when I return to the DRP, it is blank. How can I retrieve this information so that I may correct the error?

If a DRP has been linked from the BD to the IA, it would not be blank. You may have inadvertently created a new DRP by mistake. To correct this, return to the DRP list and check the IA DRP's that have an "Edit" hyperlink and verify if any DRPs are blank. Delete any DRPs that are blank and this should correct the error.

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