HELP & TRAINING

IARD System Frequently Asked Questions - Accounting

Understanding Your Registration Account

1. I work for a joint Investment Adviser/Broker-Dealer (IA-B/D) firm. Do we have separate financial accounts for registration requests?

No. A joint IA-B/D firm has one shared registration account, the Flex-Funding Account and the system deducts transactions for IA and BD registration requests from that one account. Funds deposited to the Flex-Funding Account will be available for all filings made.

2. What is the difference between the Renewal Account and the Flex-Funding Account?

The Renewal Account is the account your firm uses to pay the renewal of state registration and Notice Filing statuses. This account is only used during the renewal period, from November through February each year. The Flex-Funding Account is used to fund all other filing and registration fees.

3. When do I need to submit my Annual Updating Amendment and how much are the fees?

The Annual Updating Amendment is due within 90 days following the end of your firm’s fiscal year. Fees are charged based on your firm’s assets under management. Fees must be in your firm’s Flex-Funding Account before you can submit your filing. Check the IARD Firm System Processing Fees page for the current fees.

4. I am trying to submit a registration request(s) on behalf of my firm, but I received a Completeness Check error message indicating that my firm’s Flex-Funding Account does not have enough funds to cover the fees due with this filing. How do I determine the amount of funds needed in order to submit my firm’s filing?

In order to submit a Form ADV containing a new SEC registration, state registration(s) or notice filing(s), your account must, at the beginning of the day of submission, have a balance sufficient to pay the entire fee (if any) for those registrations or notice filings.

To determine the amount of funds needed to submit this filing, first check whether your firm has any funds available or currently due. Log onto E-Bill, the page displays a "Projected Balance" that will include all processed, pending E-Bill transactions, and funds deficient transactions. For additional information regarding E-Bill, please refer to the E-Bill User's Guide.

  • Take the Total Charges listed on the Completeness Check page for registration requests you tried to submit with the filing and:

    • If you have a credit balance above the cost of the filing, subtract the amount in your firm’s account “Projected Balance” from the Total Charges listed on the Completeness Check page
      or
    • If you have a debit balance or the credit balance is less than the cost of the filing, add the amount in your firm’s account to the Total Charges
  • This total represents the total amount of funds needed in your firm’s Flex-Funding Account to submit your firm’s filing.

Please Note: No fee is charged if an IA is state registered and submits a Form ADV to request SEC registration. Filings that do not contain any new SEC registration, state registrations or notice filings (such as those to change only the address) may be submitted with an account balance of any amount, since there is no fee.

5. What is the system processing fee for transitioning an IA representative (RA)?

Please refer to the IA Representative System Processing Fees page for information.

6. I am trying to submit registration requests on behalf of RAs with my firm, but my firm's Flex-Funding Account is showing a deficient (zero or less) balance. How do I determine the funds needed to clear the firm’s "Deficient" account status?

Log onto E-Bill, the page displays a "Projected Balance" that will include all processed, pending E-Bill transactions, and funds deficient transactions. For additional information regarding E-Bill, please refer to the E-Bill User's Guide

7. What fees apply for the IA representatives of IA-only firms?

The fees for IA representatives of IA-only firms include:

  1. Applicable IA Representative System Processing Fees.
  2. Applicable state registration fees.

Please note: There are no disclosure fees, fingerprint card processing fees, or Form U5 late filing fees for investment adviser representatives of IA-only firms.

8. When do System Processing Fees apply for IA Representatives?

Refer to the IA Representatives (RA) System Processing Fees page for complete information.

9. Where can I find a detailed monthly account report?

Log onto E-Bill, the page displays a "Projected Balance" that will include all processed, pending E-Bill transactions, and funds deficient transactions. For additional information regarding E-Bill, please refer to the E-Bill User's Guide.

10. The firm I work for holds assets in a foreign currency (i.e., pounds), how can I enter the value in IARD? Does IARD accept all types of symbols?

No, IARD does not accept all types of symbols. Form ADV explicitly states that the values must be entered in U.S. dollars. You will need to convert the foreign currency into the equivalent U.S. dollars and enter that amount.


Funding your Flex-Funding Account

11. When should I send funds for my Flex-Funding Account?

You should send funds once your firm has received its IARD Confirmation Packet, which will include your firm's CRD number. You may then submit funds and reference your firm's CRD number on your check to ensure they are deposited into your firm's Flex-Funding Account. Please DO NOT submit funds prior to receiving your IARD Confirmation Packet.

12. To whom should checks be made payable when funding my firm's Flex-Funding Account?

Make checks payable to FINRA and be sure to indicate your firm's CRD number on the check. Refer to the Payment Methods and Addresses page for additional details.

13. When should I send funds for my Flex-Funding Account?

The following methods are available and complete instructions can be found on the IARD Payment Methods & Addresses page.

  • Electronic Payment via E-Bill
  • Wire Transfer
  • Check
  • Funds Transfer

14. What is E-Bill?

E-Bill is the system for authorizing electronic payment (ACH payments) directly from a firm's designated bank account to the firm's Flex-Funding Account. FINRA will not charge firms any fees for utilizing E-Bill; however, firms should verify with their banks whether their bank assesses ACH transaction fees. Entitlement is required to use E-Bill. Complete information about E-Bill can be found on the Payment Methods and Addresses page. For additional answers to questions regarding E-Bill, please refer to the E-Bill User's Guide.

15. How do firms wire funds to their Flex-Funding Accounts?

Refer to the Payment Wire Transfers page for detailed information on wiring funds to your account.

16. What is required to transfer funds between affiliated firms or between Flex-Funding and Renewal Accounts?

Firm users with the proper entitlement and transfer privileges may transfer funds between affiliated firms at any time by using E-Bill. Additionally, firms may transfer funds from their Flex-Funding Account to their Renewal Account by using E-Bill.