IARD System Frequently Asked Questions - Transitioning for IA Firms

1. The firm I work for is federally regulated by the SEC, should I choose "Transition Notice Filing" or "Transition Registration"?

You should select "Transition Notice Filing" since your firm is SEC-registered and required to send Notice Filings to applicable states.

2. The firm I work for is state-registered only, should I choose "Transition Notice Filing" or "Transition Registration"?

You should select "Transition Registration" since your firm is state-registered only.

3. The firm I work for is federally regulated by the SEC and separately registered with a state, should I choose "Transition Notice Filing" or "Transition Registration"?

Since your firm is both SEC-registered and separately registered with a state, you will need to complete and submit both a "Transition Notice Filing" and a "Transition Registration".

4. Why must I transition my firm's current registrations before beginning my electronic Form ADV?

It is necessary to transition this information first because:

  • It prevents Registration and/or Notice Filing fees that you have already paid from being charged when you submit your Form ADV.

  • A Transition Filing cannot be submitted once you begin to create your Form ADV.

  • States will be able to validate and enter the original date of registration and/or Notice Filing to create the firm's state status history information in IARD.

5. 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.

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