How to Prepare for the 2021-2022 RIA Firm Annual Registration Renewal & Form ADV Annual Updating Amendment Season
It’s almost November, and if you manage your own investment advisor firm you know what that means. The start of the RIA Registration Renewal Season is near!
This year, preliminary renewal statements for all registered investment adviser (“RIA”) firms will be posted to E-Bill, accessible through the FINRA Gateway, on November 8, 2021. To help your firm navigate this year’s renewal process, we’ve put together the following.
The Five-Step Process for Managing Your RIA Firm Registration Renewal
Access Your RIA Firm’s Preliminary Renewal Statement
The first step in the RIA registration renewal process is to access your firm’s preliminary renewal statement. Renewal statements can only be accessed through E-Bill. You might want to set a calendar reminder so you don’t miss this important date.
It’s also important to note that all RIA firms, including new firms approved in 2021, are required to renew their firm’s registration and pay the appropriate renewal fees. Any firm that fails to pay the proper renewal fees will have its registration suspended or terminated.
Pay Your Preliminary Renewal Fees Before December 13, 2021
All RIA firms must fund their Renewal Account or Flex-Funding Account with the mandatory preliminary renewal fees by Monday, December 13, 2021. To ensure these fees get processed on time, the person responsible for managing your firm’s registration renewal should fund all preliminary fees no later than Friday, December 10, 2021.
Important Note: If you are planning to pay the renewal by check, please allow at least one week for the check to be processed by FINRA.
Pay Your Firm’s Final Renewal Fees Before January 28, 2021
On Saturday, January 2, 2022, FINRA will post every investment advisor firm’s final renewal statement through E-Bill, accessible through the FINRA Gateway. The final renewal statement will include any charges to your firm or investment advisors representatives’ registration that occurred since the posting of the preliminary renewal statement.
The deadline to pay the final renewal fees is Friday, January 28, 2021. To ensure all fees get processed on time, the person responsible for managing your firm’s registration renewal should fund all final renewal fees no later than Wednesday, January 26, 2022.
An Important Note for All SEC-Registered Firms
All RIA firms registered with the SEC need to pay the SEC Annual Registration Fee before filing the required Form ADV annual updating amendment. The fees owed are outlined in the chart below.
As a reminder, these SEC annual registration fees are charged in addition to the annual notice-filing and individual investment adviser representative (IAR) registration fees charged by the relevant states to firms registered at the federal level.
Prepare & File Form ADV Annual Updating Amendment
In addition to paying all applicable registration renewal fees for your firm and its IARs, all RIA firms, whether registered at the SEC or state level, need to prepare and file the required Form ADV annual updating amendment within 90 days after the firm’s fiscal year-end. If your firm runs on a traditional calendar year-end of December 31, 2021, you will need to file your Form ADV annual updating amendment no later than March 31, 2022.
SEC-registered firms may need to file an amendment to their firm’s Form ADV part 3 (Form CRS). The Form CRS is only required to be updated if there are material changes to its content.
Distribute Updated Form ADV Parts 2A & 2B to All Clients
RIA firms with existing clients are required to send or offer their clients an updated copy of their firm’s brochure and any brochure supplements within 120 days of their firm’s fiscal year-end. If your firm runs on a traditional calendar year-end of December 31, 2021, you will need to send your clients your updated Form ADV brochure (Part 2A) and supplements (Part 2B) by no later than April 30, 2022.
