IARD System Frequently Asked Questions - Transitioning for IA Representatives
1. What is transitioning? Why do I need to transition?
Investment adviser representatives who are currently registered with states submit a Transition Filing to create an electronic record on Web CRD with the information previously provided via paper filings, and to prevent a firm from being charged duplicate state registration fees.
2. Who should transition?
Only investment adviser representatives registered with states that require electronic registration must transition. In addition, firms may choose to file electronically. Firms should check the NASAA Web Site for state guidance related to transitioning individuals, and/or contact each state directly.
3. Who should not transition?
The following individuals should not transition:
- New individuals registering for an RA position
- RAs in states that direct individuals not to transition (contact state for information)
- RAs in states that do not register RAs (contact state for information)
4. How does a firm access the functionality to transition individuals using the Transition Screen on CRD?
Once the user has received the transition entitlement, IARD NFI Transition Registrations:
If the firm is a “joint” firm, log onto Web CRD and click on the IARD Transition Registration Search link located under Individual Non-Filing Information on the Site Map.
If the firm is an “IA-only” firm, logon to IARD and click the Web CRD hyperlink in the top left-hand corner of the screen. From the CRD Site Map select the IARD Transition Registration Search link located under Individual Non-Filing Information on the Map.
5. How does a firm access the functionality to transition individuals using the Transition Registration Request Screen in Web CRD?
IA-only firm Account Administrators became Web CRD Account Administrators automatically as of the weekend of March 16, 2002. The IA Account Administrator should be able to mark the transition functionality, the “IARD NFI Transition Registrations” privilege, for the firms’ users.
6. An investment adviser representative has transitioned onto the system. What filing does the firm need to make to complete that individual’s record on the system?
After a firm transitions an investment adviser representative onto the system, that firm should file a Form U-4 Amendment to complete the individual’s electronic record.
7. What is the fee for Transitioning?
A $45 Initial Set-up Fee is charged for each individual transitioned, in order to create an electronic registration record on the system. This fee is only charged once per individual. The Initial Set-up fee is nonrefundable.
8. Does the firm have to have the exact amount of funds in its Daily financial account to cover the $45 fee for each individual transitioned?
No, but the firm must have a SUFFICIENT account status. If the firm's account status is ”deficient” the firm will not be able to access the Transition Registration Request screen (or if Batch transition filing, the batch transition will show an error for funds).
9. What should a firm do if it realizes it forgot to add a state for an individual it has already transitioned?
The firm should access the Transition Registration Request Screen again and mark the state it missed. The $45 Initial Setup Fee will NOT be charged again.
10. Does a firm have to wait for a state to approve an individual who has transitioned before submitting the Form U-4 Amendment filing for the individual?
No. The firm may submit the Form U-4 Amendment filing before a state approves the Transition Filing.
11. What is the RA registration status when an investment adviser representative has been transitioned? Is this an active status?
The registration status is “TRANS_RQST” and is an active status.
12. What is the registration status for an individual that has been transitioned in a state by mistake?
The RA registration status is “TRANS_ERROR”. The state sets this status for any individual that should not have been transitioned in that jurisdiction.
13. Why is the "Approval Date" appearing with the TRANS_RQST status and the "Approval Date" is identical to the TRANS_RQST Status Date?
This is a display issue and will be fixed in a future release. If the “Approval Date” is identical to the TRANS_RQST Status Date AND the “TRANS_RQST” status is displaying, the state has not yet acted upon the registration request for the individual.
14. An individual is registered as an AG with Firm A. Additionally, the individual is registered as an RA with an IA Firm, Firm B. Firm B transitions the individual onto the system. What filing type should Firm B choose to update the individual’s record?
Firm B should file a Form U-4 Amendment for that individual, in order to update the individual’s record with that IA firm.
15. Firm A and Firm B are affiliated, and both firms are “Joint” BD/IA firms. An individual is registered as an AG and as an RA with both Firm A and Firm B. Should both firms transition that individual?
Yes. Both Firm A and Firm B should transition the individual.
16. Why am I unable to select some of the states on the on the Transition Registration Request Screen?
The states that can be selected indicate that the firm has an active registration or Notice Filing status in those states. The states that cannot be selected indicate that the firm does not have an active registration in those states. In addition, states that did not register investment adviser representatives prior to Release 4.0, which was implemented March 18, 2002, do not appear on the grid.
17. Can I transition into states that do NOT currently register investment adviser representatives?
No. Those states that do not currently register investment adviser representatives do NOT appear on the jurisdiction grid of the Transition Registration Request screen.
18. What should the firm do if the firm transitions an individual in error (i.e., marks a state in error)?
The firm should file a Partial Form U-5 to terminate the transition registration(s) submitted in error. If the individual is only transitioned in one state, the firm should submit a Full Form U-5. The Initial Set-up Fee of $45 is nonrefundable.
19. After a firm transitions an individual onto Web CRD, does the firm need to file a Form U-4 Amendment for the individual?
Yes and no.
If the individual transitioned is registered as both a Registered Representative (RR) and an Investment Adviser Representative (RA), a Form U-4 Amendment is NOT necessary, because the individual’s electronic Form U-4 should already exist in Web CRD for the RR position and will now share the record for the RA position as well.
If the individual is solely an Investment Adviser Representative (RA), the firm will need to file a Form U-4 Amendment. Transitioning this type of individual only establishes a base CRD record so that states may validate current registration statuses held and the firm may avoid paying duplicative registration fees. The submission of an electronic Form U-4 Amendment for this individual is necessary to complete the electronic registration record.
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