IARD System Frequently Asked Questions - Renewal Program
|Note: The dates below refer to the 2021 Renewal Program, which ended January 22, 2021. Check back in the fall for dates and details related to the 2022 Renewal Program.|
- Does FINRA mail Preliminary and Final Statements?
- Are there any changes to the Renewal Program that my firm should be aware of?
- What renewal fees will be reflected on my firm's renewal statement?
- I logged onto E-Bill to retrieve my firm's Preliminary Statement, but there wasn't one available. Why doesn't my firm have a statement?
- What is the deadline for submitting payment of my Preliminary Statement?
- What renewal payment methods are accepted?
- To whom should a renewal payment check be made payable and mailed?
- Will the amount of my Preliminary Statement change before the payment deadline date if I modify the firm’s registrations?
- If I pay my Preliminary Statement in full, have I fulfilled all my renewal fee obligations and completed the renewal process?
- How do I check to see that FINRA has received my renewal payment?
- How can I transfer money from my Flex-Funding Account to my Renewal Account?
- My investment adviser (IA) firm and broker-dealer (BD) firm have the same CRD Number. Am I considered a "joint" firm?
- How do I obtain a report that shows a list of everyone at my firm who was included for renewals?
- Will my Firm Renewal Report be automatically generated and sent to me?
- My firm submitted a post-dated Form U5 for an individual by mistake. Can we withdraw or cancel that filing?
- What is the last day that I can submit an electronic form filing in CRD/IARD before year-end renewal processing occurs?
1. Does FINRA mail Preliminary and Final Statements?
Renewal Statements are not mailed to firms. Statements will be available via E-Bill for retrieval and printing. The Preliminary Statement will be available online on Nov. 16, 2020, and the Final Statement will be available Jan. 2, 2021.
2. Are there any changes to the Renewal Program that my firm should be aware of?
There are no changes to the 2021 Renewal Program.
3. What renewal fees will be reflected on my firm's renewal statement?
Renewal statements will reflect the jurisdiction-related and annual system processing renewal fees for all firms, branches and representatives. Please refer to the IA Representative Fee Schedule, IA Firm Fee Schedule IA Representative System Processing Fees and the IARD Firm System Processing Fees web pages for additional information.
Note: SEC-related fees are not collected during this annual Renewal Program. See the IARD Firm System Processing Fees page for more information.
4. I logged onto E-Bill to retrieve my firm's Preliminary Statement, but there wasn't one available. Why doesn't my firm have a statement?
FINRA only collects state/jurisdiction fees and FINRA fees through the Renewal Program. An approved firm IA state registration or notice filing status in CRD/IARD is required to generate a Preliminary Statement. If your firm had a 'Pending Approval' or another registration status other than ‘Approved’ in CRD/IARD as of 11 p.m., ET, Nov. 13, 2020, then a Preliminary Statement was not generated for your firm. However, a Final Statement will be generated for your firm if your firm becomes approved between Nov. 16 and Dec. 26, 2020. If this should occur, your firm's renewal fees will be assessed and collected with your Final Statement, which will be available on Jan. 2, 2021. SEC-registered firms that do not notice file or request exempt reporting status with a jurisdiction will not receive a renewal statement.
5. What is the deadline for submitting payment of my Preliminary Statement?
Full payment of your Preliminary Statement must post to your firm's Renewal Account by Dec. 14, 2020, even if your firm intends to terminate additional IA registrations before Dec. 31, 2020. Firms should submit their electronic (i.e., E-Bill, wire transfer) payments no later than Dec. 9 for payment to post to their Renewal Account by the Dec. 14 deadline.
6. What renewal payment methods are accepted?
E-Bill allows entitled users to view and pay Renewal Statements and fund their firm's accounts. E-Bill is the only payment method available to directly fund the Renewal Account. Firms can also transfer funds to their Renewal Account or to an affiliated firm’s Flex-Funding Account via E-Bill, please see the E-Bill User Guide for complete information.
Firms may also continue to submit renewal payments by wire transfer or check. Visit the IARD Accounting page for complete information.
7. To whom should a renewal payment check be made payable and mailed?
Firms should make their checks payable to FINRA. As the operator of IARD, FINRA will collect fees on behalf of the jurisdictions and then disburse the fees to the appropriate jurisdictions. It is also important for firms to reference the firm CRD number on the memo line to ensure timely deposit of funds to their Flex-Funding account. For details regarding the mailing address and processing of check payments, visit the IARD Accounting page.
No, a Preliminary Statement is assessed based on information from CRD/IARD as of 11 p.m., ET, on Nov. 13, 2020. Any changes for new and/or terminated registrations requested between that date and the system shutdown on Dec. 26, 2020, will be reflected on your Final Statement on Jan. 2, 2021.
No. Since the Preliminary Statement is based on the registration statuses of your firm, its individuals, and branches as of Nov. 13, 2020, any changes to those registrations prior to year-end have not yet been considered for renewal purposes. Therefore, the renewal process is not complete until reconciliation occurs through your firm's Final Statement, which will become available in E-Bill Jan. 2, 2021. For firms that have an amount due, FINRA must receive your payment no later than January 22, 2021. The Final Statement will list one of the following:
- Zero balance due by your firm (no further action required by your firm)
- An amount due by your firm (send payment)
Renewal payments made electronically using E-Bill or wire transfer typically take two to three business days to process and post to your account, after which you can view E-Bill to verify receipt.
For complete renewal payment information, visit the IARD Accounting page.
Firms may transfer funds to their Renewal Account or to affiliated firms by using E-Bill. Direct payment or transfer of funds into the Renewal Account ensures that the allocated renewal funds are not spent on registration transactions. See the E-Bill User Guide for complete instructions.
Automatic transfers are also implemented during the Annual Renewal Program when a firm has sufficient funds in the firm’s Flex-Funding Account to cover the total outstanding renewal fees due. These automatic transfer periods begin on payment deadline dates (Dec. 14, 2020, and Jan. 22, 2021), to ensure that funds are available for registration transactions in the Flex-Funding Account throughout the Renewal Period.
Yes, your firm's Preliminary and Final Statements will reflect your applicable BD and IA firm, branch and representative renewal fees. For additional information regarding broker-dealer renewals, visit the FINRA Renewal page.
This information is available as part of the "Firm Renewal Report." The report is available as a PDF or a download. To request this report, log onto IARD and select the Reports tab. Detailed instructions are provided in the IARD Bulletin; see the IARD Reports Quick Reference Guide for navigational assistance.
No, Renewal Reports can be retrieved via the IARD Reports tab. See the Firm Renewal Report Guide to learn how firms can use the Renewals - Firm Renewal Report and Download to identify the fees assessed per registered individual.
No, CRD/IARD processes all filings as they are submitted. If a post-dated Form U5 is submitted by mistake, then a new Form U4 or a Form U4 amendment must be submitted on or after Jan. 2, 2021, to re-register the IA representative and applicable registration fees will be assessed.
All form filings must be submitted to CRD/IARD by 6 p.m., ET, Dec. 26, 2020. The Web EFT deadline is 3 p.m., ET. CRD/IARD will be unavailable to submit any filings from 6 p.m., ET, Dec. 26, 2020, through Jan. 1, 2021, due to year-end Renewal processing. From Dec. 28 through Dec. 31, 2020. CRD/IARD will be available for query only and to create "Pending" filings, which must be submitted on or after Jan. 2, 2021. The IARD Availability Schedule covers the current schedule.