IARD System Frequently Asked Questions - Form Filing for IA Firms
Schedule A/B

1. How do I remove a person from Schedule A or B?

The first sentence that will appear on an existing control person's record is: "Check here to terminate this Owner." To remove a person from Schedule A or B, check the Check Box next to this sentence and click "Save" to submit the change. Keep in mind that there must be at least one direct owner on Schedule A at all times.

2. I need to list an individual on Schedule A or B, who is a foreign national and does not have a CRD Number or a U.S. Social Security Number. What should I do?

You should contact the Gateway Call Center at (240) 386-4848 and a customer satisfaction representative will establish a CRD Number for that foreign individual.

3. I need to list a foreign entity on Schedule A or B, but it does not have an IRS Tax Number or an Employer ID Number. What should I do?

You should type 'Foreign Entity' in the data field box that requests a CRD Number. The IARD system will accept this as a response.

4. I need to list a trust on Schedule A or B, but the trust does not have a CRD Number. What should I use as the identification number for the trust?

You should use its IRS Tax Number.

5. How do I create a Schedule A & B when the owner/officer is an individual?

Follow these steps:

  • Select the "New Individual" button.
  • Enter identifying information in the individual search screen.
  • The system will search for matches to the search criteria provided.
    • Make sure the Social Security Number, CRD Number, or Name you enter for the search is correct, so that you do not create a new individual record for an existing individual by mistake.
    • If the individual doesn't already exist on the system, it will be created.
    • If one or more matches are found, each will be shown in a list and one may be selected by clicking on the individual name.
  • Enter the other schedule information.

6. How do I create a Schedule A & B when the owner/officer is an entity?

Follow these steps:

  • Select the "New Entity" button.
  • Enter the required schedule information.
  • When the filer has entered and saved the information, the information can be viewed in the format of the form schedule using the "Print Preview" function.

7. Why would Part 1B show up when the Form ADV is printed but not on IARD when I'm completing the electronic Form ADV?

Part 1B is a portion of the Form ADV, which is only required of a state-registered IA firm. If your firm is SEC-registered only, you would not be required to answer Part 1B and it will not appear while you are filing your Form ADV on IARD.

8. My firm is SEC-registered only but the system expects me to complete Part 1B, which only applies to state-registered firms. What happened and what should I do?

You may have either inadvertently selected "Initial State Registration" instead of "Initial SEC Registration" when selecting your Form ADV type or submitted a "Transition Registration" when you were supposed to submit a "Transition Notice Filing."

  • If you selected "Initial State Registration" by mistake, and have not yet submitted Part 1A, then you can delete the pending filing and begin a new filing for "Initial SEC Registration." If you have already submitted Part 1A as seeking "Initial State Registration," then you should contact those states to request they reset your firm's registration status. Delete the filing with the Part 1B and begin a new filing for "Initial SEC Registration."

  • If you submitted "Transition Registration" instead of "Transition Notice Filing" then you have indicated that your firm maintains a state registration and therefore, requires you to complete Part 1B. In order to remedy the situation, review your firm's Transition Filing and determine which states you filed a "Transition Registration" in error. Contact those states to request they reset your firm's registration status to "Not Transitioned." Delete the filing with the Part 1B and begin a new filing. You should no longer be asked to complete Part 1B, as long as all the state registration statuses show "Not Transitioned."

9. Is it possible for me to submit a Form ADV without Schedule A?

No. It is not possible to submit a filing without this information. You will receive a Completeness Check error advising you to complete Schedule A.

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