What Follows Once You Have An IARD Account
Your Firm Should Do The Following:
Once the Account Administrator(s) and the firm's users have been entitled to the IARD system, your firm should:
- Send funds to your firm's IARD financial account.
- Funds must be on deposit in your IARD financial account before you can submit your first electronic Form ADV.
- Required funds should cover your firmís IARD Initial Set-Up Fee and any fees associated with new state Notice Filings or state registrations.
- Once your firm has registered electronically, determine whether you will be registering your firmís IA representatives and be sure to deposit funds to cover your IA representativesí Initial Set-Up Fees and any applicable registration fees.
- View additional information regarding IARD Fees and Accounting.
- Determine the appropriate filings to register your firm.
- Firm Transition Filing: If your firm is currently registered with states/jurisdictions via paper filings and changing to electronic filing then your firm should first submit a Transition Filing before you begin to create your electronic Form ADV on IARD. A Transition Filing accomplishes two things:
- Avoid duplicative fees: It enables your firm to create an electronic record of existing registrations for which it has already paid state/jurisdiction registration fees, so as not to be charged these fees again when submitting your firmís first electronic Form ADV.
- Original effective date of registration: It enables regulators to enter the original effective date of your firmís Notice Filing or state registration.
- Form ADV (Initial, Annual Amendment, or Other-Than Annual Amendment): Be sure to understand which Form ADV filing type should be your firmís first electronic Form ADV.
- Logon to the IARD system and begin creating your electronic Form ADV. When creating your electronic Form ADV, you should be aware of the following tips:
- In order to assist in creating your first electronic Form ADV, these filings can be saved in draft form as a ďpendingĒ filing for a period of 120 calendar days in the IARD system.
- The "pending" Form ADV filing can only be accessed by entitled users at your firm and cannot be viewed by either FINRA or the applicable regulators until after they are officially submitted.
- If the "pending" Form ADV filing is not submitted after 120 days, the system will automatically delete it.
- When you have completed your Form ADV be sure to run the IARD system's "Completeness Checks" to identify any problems with the filing data.
- Correct any errors or omissions that the "Completeness Checks" alert you of before you submit the filing.
- Once your filing has passed the "Completeness Checks," you may submit your electronic Form ADV.
- The SEC and/or States will review your firmís filings.
- The states will review the data you filed as part of your Transition Filing (if applicable) and enter, on your firm's IARD record, the original effective date of your firm's Notice Filing or state registration.
- The SEC effective date is already captured in the system as part of FINRA's initial set-up processing.
- The SEC and states will review your electronic Form ADV and will communicate directly with you about any deficiencies they may find in their review process.
- Determine the appropriate filings to register your firmís IA representatives: IA firms should register their IA representatives electronically on the Web CRD system as directed/mandated by states/jurisdictions; additionally, firms may voluntarily register their IA representatives via Web CRD as all of the states/jurisdictions will accept these electronic form filings for IA representatives.
- IA Representative Transition Filing: If your firmís IA representatives are currently registered with states/jurisdictions via paper filings and changing to electronic filing then your firm should first submit Transition Filings before begin to create your electronic Form U4 on Web CRD. A Transition Filing will accomplish two things:
- Avoid duplicative fees: It enables your firm to create an electronic record of your IA representativesí existing registrations for which it has already paid state/jurisdiction registration fees, so as not to be charged these fees again when submitting the IA representativesí first electronic Form U4s.
- Original effective date of registration: It enables regulators to enter the original effective date of your IA representativesí registrations.
- Form U4: Be sure to understand which Form U4 filing type should be your IA representativeís first electronic Form U4.
- Continue to maintain your firm and/or IA representativesí filings with future electronic filings.
- Make all future amendments to Form ADV via the IARD system.
- SEC-filing firms must file their Annual Amendment within 90 days following the end of their fiscal year. The Annual IARD System Fee will be charged when firms file their Annual Amendment.
- State-filing firms may also be required to file an Annual Amendment; however, the Annual IARD System Fees will be charged during the December Renewal period when state filing fees for the new year are collected by FINRA and dispersed to the appropriate states.
- Make all future amendments to Form U4 via the Web CRD system.
- Remember to ensure your firm's financial account has sufficient funds on deposit to cover system processing fees and any applicable filing fees.
- The IARD Renewal Program will begin in November of each year to renew the registration of your firm and/or IA representatives with states/jurisdictions for the following year.
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