WELCOME TO THE INVESTMENT ADVISER REGISTRATION DEPOSITORY
Welcome to the IARDTM website. This site provides investment adviser firms and representatives with a variety of information about the Investment Adviser Registration Depository (IARD) system. IARD is an electronic filing system that facilitates investment adviser registration, exempt reporting adviser filing, regulatory review, and the public disclosure information of registered investment adviser firms and individuals. FINRA is the developer and operator of IARD. The system has been developed according to the requirements of its sponsors, the Securities and Exchange Commission (SEC) and the North American Securities Administrators Association (NASAA), along with those of an Industry Advisory Council representing the investment adviser firms.
Information about investment advisers for the investing public can be found on the Investment Adviser Public Disclosure (IAPD) website.
IARD/PFRD System Availability
IARD and PFRD are generally available from 5 a.m. to 11 p.m. Eastern Time, Monday through Friday. Please refer to the IARD/PFRD Availability Schedule for detailed weekend and holiday availability.
What's New on IARD
Please look to this area of the home page on a frequent basis for regular updates, new information, and documents about how to use IARD.
System Release Notes
View explanations of recent and upcoming system changes in the release notes linked below:
- Release Notes 2021.07 (July 31, 2021)
See the System Updates page for more information.
New York IAR Registration – Updated July 23, 2021
Effective February 1, 2021, the State of New York (NY) began registering Investment Adviser Representatives (IARs) in CRD. On February 1, Forms U4 and U5 were updated to allow firms to select, under Section 5 of Form U4, RA registration in NY. While Web EFT is being updated, it is recommended that firms not use EFT to request NY IAR Registrations until the transition is completed. The system will go back to the default requirements on September 7.
- From February 1 until July 30, 2021, NY will offer both noticed and registered NY investment adviser firms an offline “mass registration” process in an effort to help facilitate bulk RA registration. By utilizing this off-system process, firms can ensure that NASAA’s Series 65 examination windows/enrollments will not systematically generate in CRD for those individuals who may otherwise be waived by NY from taking (or re-taking) the Series 65. See the full announcement for detailed information.
- Beginning February 27, 2021, FINRA Gateway will be temporarily updated so that windows for NASAA’s Series 65 examination will not systematically open when NY RA is the only registration requested on the filing (selection of other RA registrations will trigger any necessary exam requirements). If an individual requesting NY RA needs to take the Series 65, the firm will need to explicitly select the exam in Section 7 of Form U4 in order for the enrollment/window to be generated and the applicable fee to be charged. The automatic generation of Series 65 enrollments/windows when NY RA is requested will be re-enabled at a future time.
- FINRA Gateway Reports now offers templates designed to support firms throughout the NY RA registration process. The four new report templates identify individuals who:
- may be subject to the registration requirement,
- have a NY RA registration requested,
- have an approved NY RA registration, and
- have opened an exam enrollment.
For more information, see the FINRA Gateway Reports page.
Form ADV Annual Updating Amendment Deadline
Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) and a fiscal year end of Dec. 31, 2020, are required to submit their annual updating amendment online via IARD by March 31, 2021. Please ensure that your firm has sufficient funds in its FINRA Flex-Funding Account to cover the system processing fee owed in order to submit your amendment filing within the 90 day filing requirement. Please review the payment options and instructions for funding your firm's Flex-Funding Account. If you have questions, please email [email protected].
Form U4 Retires in Classic CRD and Available Exclusively in FINRA Gateway Starting April 5. Form U5 Comes to FINRA Gateway May 17.
- The deadline to submit Form U4 in Web CRD is April 4, 2021. A read-only version will be made available through May 15 for any pending drafts that were not submitted on or before April 4. Firms are encouraged to submit Form U4 drafts in Web CRD, or recreate them in FINRA Gateway, before the April 5 retirement deadline. See the Registration Filing in FINRA Gateway page for more details. All other features in Classic CRD will remain available.
Form U5 comes to FINRA Gateway May 17. Firms are encouraged to begin using the FINRA Gateway U5 filing experience and to provide feedback. Form U5 filing functionality in Classic CRD will retire no earlier than August 21, 2021.
FINRA's 2021 Entitlement User Account Certification Process
FINRA’s Annual User Accounts Certification Period concluded July 19, 2021. Super Account Administrators for organizations with more than one user and/or administrator account that have not yet certified must do so immediately. The ability to create, edit and clone accounts has been disabled and will remain so until certification is completed. Failure to certify will result in the appropriate regulator(s) being contacted and the disabling of all accounts. For detailed information, refer to the Annual Entitlement User Accounts Certification Process page.
Enhanced Entitlement Security Feature — Multi-Factor Authentication (MFA) Rollout
Multi-Factor Authentication (MFA) continues to be rolled out to firms' Super Account Administrators and Account Administrators. In 2020, FINRA began deploying this new security feature as an additional layer of security to verify user identity. MFA is an authentication method in which a user is granted access to FINRA-operated systems (e.g., IARD, CRD) only after successfully providing two pieces of identifying information:
- existing FINRA system (IARD/CRD) credentials (user name and password); and
- new MFA security feature (three options to provide second authentication factor):
- mobile application,
- text message, or
- phone call.
For more information, visit the Multi-Factor Authentication page.
Payroll Protection Program and Form U4
On April 13, 2020, FINRA issued guidance (found in the Individual Registration Q&A section) stating that a registered person who obtains a loan under the Paycheck Protection Program (PPP) will not have to disclose a “compromise with a creditor” in response to Question 14K on Form U4 if the loan is wholly or partially forgiven under the terms of the PPP. The NASAA CRD/IARD Steering Committee consulted with FINRA regarding this guidance. We concur with it and further advise that the same guidance would apply to Question 14K on Form U4 for an investment adviser representative who obtains a PPP loan.
COVID-19 Update for Investment Adviser Representative (RA) Qualification Exam Candidates
COVID-19 guidance on FINRA-administered exams (Series 7, 65 and 66 for RAs*) has been posted. Information regarding test center availability, exam cancellations and enrollment window extensions will be updated as it becomes available. Please check frequently and encourage exam candidates to consult the page before enrolling, scheduling or sitting for their exams.
*Please note that FINRA administers state law exams on behalf of NASAA.
Browser Support Update
Effective April 4, 2020, FINRA ceased to support Internet Explorer 11 for the IARD, PFRD and CRD systems. You or your firm should upgrade your web browser if it does not meet or exceed the following minimum browser requirements. You can check your current web browser at https://whatsmybrowser.org.
Protect Personal Information! Remember to only provide personal information about individuals in response to specific questions that solicit that information. When responding to more general questions that accept narrative responses, use terms that do not disclose personal information (including account numbers). Please review the guidance provided on the Protecting Personal Information in Form ADV Filings page for more information.
Investment Adviser Representative Fingerprint Submissions
FINRA does not process fingerprint transactions for investment adviser (IA) firms. An IA-only firm must submit fingerprints directly to those states that require a fingerprint check for an RA registration. Contact the applicable state to verify state fingerprint requirements. Fingerprint submissions received by FINRA from an IA-only firm will not be returned to the firm.
FINRA.org: Add to Safe-Sender Email List
FINRA is the operator of IARD on behalf of the IARD program sponsors which are the SEC and NASAA. In order to ensure consistent delivery of FINRA emails to your inboxes, please add our email domain, FINRA.org to your firm's safe-sender list as soon as possible. Please review this Subscriptions Help page for instructions on how to add email addresses/domains to your firm’s specific email application. If your email application requires you to enter individual email addresses to your safe-sender list in addition to, or in lieu of, an email domain, please add the following addresses:
Also, if you are an SEC-registered IA firm, please add: [email protected]
Form ADV-E Guidance for Independent Public Accountants
A quick reference guide to the Form ADV-E Surprise Examination Filing website is now available for independent public accountants conducting a surprise inspection of an investment adviser firm.
SEC Division of Investment Management: Electronic Filing for Investment Advisers on IARD
Visit the SEC website for information on IARD.