The U.S. Securities and Exchange Commission (SEC) recently approved the registration of several investment adviser firms based in Israel. This is a notable development given the longstanding data protection concerns that previously complicated registration efforts by advisers operating under Israel’s privacy framework.
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]]>Israel’s data protection laws—primarily the Protection of Privacy Law and associated regulations—are broadly aligned with EU-style privacy frameworks such as the General Data Protection Regulation (GDPR). These laws impose restrictions on the transfer of personal data outside of Israel, particularly where foreign governmental authorities are involved.
These privacy restrictions have led to uncertainty about whether Israeli-based investment advisers could fully comply with the SEC’s obligations under Section 204 of the Investment Advisers Act of 1940, which requires all registered investment adviser firms—regardless of domicile—to make their books and records available for SEC examination. This uncertainty contributed to the SEC’s informal pause on new investment adviser registrations from certain foreign jurisdictions, including Israel, where examination access was unclear.
The SEC’s recent approvals appear to confirm that, in at least certain cases, it is now satisfied that Israel’s legal framework permits the necessary level of cooperation to support oversight of a registered investment adviser based in Israel.
These approvals provide an important precedent. It seemingly shows that SEC registration in the U.S. is possible for Israeli-based investment adviser firms, provided the SEC determines it can carry out its examination and enforcement functions in accordance with U.S. law.
Investment advisers located in Israel who have U.S. clients—or who plan to expand their services to U.S. clients—may now have a clearer path forward. However, this does not indicate a blanket shift in policy. It is our belief that the SEC is likely to continue reviewing applications on a case-by-case basis.
An Israel based investment adviser firm pursuing registration in the U.S. should prepare a comprehensive readiness package:
Legal opinion from Israeli counsel addressing exam access under Amendment 13 to Israel’s Protection of Privacy Law;
Data-mapping and retrieval protocols showing how books/records will be produced on demand;
Updated privacy notices, client agreements, vendor agreements, and incident response plans disclosing obligations to share with the SEC and reflecting Amendment 13 obligations;
ADV-NR filing and a reliable U.S. agent for service of process;
AML/BSA procedures in advance of the 2028 effective date for the U.S. Treasury Department’s AML rules for investment advisers; and
Marketing Rule compliance systems for U.S.-facing advertising, testimonials, and performance materials.
The SEC recently announced a Cross-Border Task Force to combat fraud targeting U.S. investors. This appears to mean that while the SEC is opening registration channels, it is simultaneously raising its enforcement profile on cross-border matters. Foreign investment advisers should assume that registration in U.S. will bring them into sharper focus, not less.
The SEC’s approval of Israeli-based advisers is a significant but qualified development. Registration appears achievable, but it is presumably conditioned on exam access assurances, privacy compliance, and enhanced cross-border oversight. Advisers should see this as both an opportunity and a compliance test. While challenges remain and approvals are not automatic, we believe that this outcome demonstrates that Israeli data protection laws do not inherently preclude SEC registration (at least when the applicable foreign regulator provides written guidance offering relief). For Israeli investment advisers seeking to serve U.S. clients, now may be an appropriate time to revisit the possibility of SEC registration, particularly in light of evolving interpretations and increased regulatory cooperation.
This regulatory alert is a summary which is general in nature and offered only for educational purposes. There is no warranty associated with this regulatory alert. It should not be considered as a comprehensive review or analysis of this development. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. There may be additional obligations and nuances not covered here. Each investment adviser firm is unique, and specific guidance may be required to address your firm’s circumstances. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor or a legal opinion. Merely reading this regulatory alert does not create an engagement with RIA Compliance Consultants, Inc. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
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]]>If your investment adviser firm is required to file Form 13F, please be aware that your firm is also required (subject to certain exceptions) by the U.S. Securities and Exchange Commisson (“SEC”) to file an annual report on Form N-PX each year. The deadline to file Form N-PX is August 31.
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]]>This report will cover the most recent 12-month period ending June 30 and must inlude the firm’s proxy voting record related to executive compensation (“say-on-pay”) matters.
Even if your investment adviser firm is a 13F filer that does not vote proxies, it is still required to submit Form N-PX, indicating that no proxy voting occurred during the reporting period.
However, if your investment adviser firm does not exercise investment discretion over $100 million in 13F securities and is therefore not required to file Form 13F, your firm is not required to file Form N-PX.
For further details, you can review the full text of the SEC’s final rule here: SEC Final Rule: Form N-PX.
Investment Advisers Filing Form 13F, N-PX or 13H Must Enroll in New System
SEC Fines Investment Adviser for Failure to File Form 13F
FAQs: Form 13F, Form SH, Schedule 13D & Schedule 13G
SEC Proposed Changes to Form 13F for Institutional Investment Managers (8/3/2020)
Deadline Approaching for Filing the Form 13F with the SEC (1/12/2015)
SEC Settles a Form 13F Filing Violation for a $100,000 Penalty (8/16/2007)
This regulatory alert is a brief summary which is general in nature and offered only for educational purposes. It should not be considered as a comprehensive review or analysis of this rule. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor or a legal opinion. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
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]]>For many years, the U.S. Securities and Exchange Commission (SEC) has maintained that, in order to register a non-U.S. investment adviser firm under the Investment Advisers Act of 1940, it must be able to access the registrant’s books and records for examination purposes.
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]]>For many years, the U.S. Securities and Exchange Commission (SEC) has maintained that, in order to register a non-U.S. investment adviser firm under the Investment Advisers Act of 1940, it must be able to access the registrant’s books and records for examination purposes.
This requirement became more complex following the implementation of the European Union’s General Data Protection Regulation (GDPR) in 2018. The GDPR introduced stringent data privacy protections, including strict limitations on the cross-border transfer of personal data—particularly to non-EU regulatory authorities. In response, many countries outside the EU adopted similar laws, often referred to as GDPR-style privacy frameworks, to strengthen local data protection standards.
To ensure it could fulfill its oversight responsibilities, the SEC began pausing the processing of new registration applications from investment adviser firms with a principal place of business in foreign jurisdictions where it was uncertain whether it could lawfully obtain the information necessary to conduct examinations.
In June 2025, the SEC announced in Press Release No. 2025-83 that it had resumed processing new registration applications for investment advisers based in Switzerland. This decision followed the creation of a cooperative arrangement between the SEC and the Swiss Financial Market Supervisory Authority (FINMA).
This new framework allows the SEC to conduct oversight of Swiss-based registrants without violating Swiss privacy and data protection laws. Accordingly, Swiss investment advisers that had previously encountered registration delays or uncertainty may now resume the registration process with the SEC.
Investment adviser firms located in foreign jurisdictions where cross-border privacy issues previously limited or prevented registration efforts can now reassess whether SEC registration is a viable strategic option.
In the absence of the SEC registration path, some investment adviser firms have relied on alternative structures to serve U.S. clients, including:
Each of these alternatives carries its own regulatory, operational, and legal challenges. Depending on the specific circumstances, some of these alternatives may not be available or impose constraints that limit scalability or service flexibility. This blog post does not recommend or endorse any particular structure or strategy but instead encourages foreign adviser firms to carefully evaluate the current viability of SEC registration in light of recent developments.
While these structures may remain feasible depending on the firm’s business model, full SEC registration provides notable advantages, such as:
Foreign-based investment adviser firms contemplating SEC registration should take the following steps:
This recent action by the SEC reflects a pragmatic approach that recognizes the importance of regulatory cooperation, while still honoring its statutory obligations. However, this is not a blanket opening to all jurisdictions with GDPR-style privacy and data protection laws, but rather a targeted outcome based on jurisdiction-specific legal accommodations permitting the sharing of U.S. client data with the SEC. For foreign investment adviser firms that previously deferred SEC registration due to privacy-based uncertainty, now may be the time to reassess.
This regulatory alert is a summary which is general in nature and offered only for educational purposes. There is no warranty associated with this regulatory alert. It should not be considered as a comprehensive review or analysis of this development. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. There may be additional obligations and nuances not covered here. Each investment adviser firm is unique, and specific guidance may be required to address your firm’s circumstances. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor or a legal opinion. Merely reading this regulatory alert does not create an engagement with RIA Compliance Consultants, Inc. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
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]]>If your investment adviser firm submits filings such as 13F, N‑PX, or 13H, you must enroll in EDGAR Next by September 12, 2025 to avoid disruption. The U.S. Securities and Exchange Commission (“SEC”) will replace legacy CIK/CCC and passphrase authentication with Login.gov individual accounts and multifactor authentication.
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]]>EDGAR Next enrollment can continue after Sept 15, 2025, but filing access will be blocked until enrollment is complete. After December 19, 2025, only newly granted Form ID applications will restore access.
For detailed guidance, SEC resources including step‑by‑step instructions, FAQs, and instructional videos are available at: https://www.sec.gov/submit-filings/improving-edgar/edgar-next-improving-filer-access-account-management
If you plan to delegate enrollment or account setup to a third party (like Securex), coordinate carefully now – Securex is not assisting with setting up EDGAR Next at this time, so you must do it internally or through another trusted advisor.
Deadline Approaching for Filing the Form 13F with the SEC (01/19/2025)
SEC Fines Investment Adviser for Failure to File Form 13F
FAQs: Form 13F, Form SH, Schedule 13D & Schedule 13G
SEC Proposed Changes to Form 13F for Institutional Investment Managers (8/3/2020)
SEC’s Deadlines for Filing Form 13F in 2015 (1/4/2015)
Deadline Approaching for Filing the Form 13F with the SEC (1/12/2015)
SEC Settles a Form 13F Filing Violation for a $100,000 Penalty (8/16/2007)
This regulatory alert is a brief summary which is general in nature and offered only for educational purposes. It should not be considered as a comprehensive review or analysis of this obligation. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
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]]>On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a significant delay to the compliance deadline for its long-awaited anti-money laundering (AML) rule applicable to certain investment advisers. Originally set to take effect on January 1, 2026, the rule’s new effective date is January 1, 2028. In the meantime, FinCEN has indicated it will reconsider the scope and requirements of the rule, along with a jointly proposed Customer Identification Program (CIP) rule developed with the U.S. Securities and Exchange Commission (“SEC”).
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]]>The AML rule, published in September 2024, would have applied to the following:
The AML rule did not cover the following type of firms:
The AML required covered investment advisers to implement formal AML programs consistent with Section 352 of the USA PATRIOT Act, which includes:
Although this rule mirrored the structure applied to broker-dealers since 2002, it posed considerable implementation challenges for investment advisers – especially smaller firms that have never been subject to formal AML obligations.
FinCEN cited the need to ensure that the final rule is “effectively tailored to the diverse business models and risk profiles” in the investment adviser space and “balances regulatory obligations with operational realities.” The agency also committed to re-engaging with industry stakeholders to refine the rule’s scope before enforcement begins.
The delay comes after extensive feedback from trade groups and compliance professionals requesting longer timelines and more targeted obligations – particularly for investment adviser firms that do not custody client funds or offer direct wire transfer capabilities.
If your investment adviser firm has never implemented an AML program, this delay provides a window of opportunity—but not an excuse for inaction. Here’s how to proceed strategically:
Even without a formal obligation under federal AML regulations, your investment adviser firm may be exposed to the following:
This is a prime opportunity to begin developing scalable AML infrastructure:
FinCEN has announced plans to issue temporary exemptive relief and reopen the comment period. At that point, your investment adviser can provide comments. The updated rule could result in the following:
RIA Compliance Consultants previously recorded a detailed investment adviser representative continuing education (“IAR CE”) course on the original AML rule for investment advisers, which provides helpful insight into the structure and logic of the initial regulation – even if coverage or elements may change. Watch the course here.
We are closely tracking all FinCEN updates regarding the AML rule for investment advisers. To stay informed, sign up for our newsletter or contact us for support in preparing your firm’s AML program.
Ethics & Professional Responsibility: New AML Requirements for Investment Advisers
Investment Advisers May Be Required to Implement Anti-Money Laundering Policies and Procedures
This regulatory alert is a summary which is general in nature and offered only for educational purposes. There is no warranty associated with this regulatory alert. It should not be considered as a comprehensive review or analysis of this development. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. There may be additional obligations and nuances not covered here. Each investment adviser firm is unique, and specific guidance may be required to address your firm’s circumstances. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor or a legal opinion. Merely reading this regulatory alert does not create an engagement with RIA Compliance Consultants, Inc. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
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]]>A recent jury decision in a Securities and Exchange Commission (SEC) enforcement action underscores the risks and complexities facing investment adviser firms whose representatives also hold insurance licenses and sell fixed indexed annuities (FIAs) to advisory clients.
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]]>The SEC recently secured a jury verdict against an investment adviser firm and its representative for breaching fiduciary duties, primarily through inadequate disclosure of substantial commissions from FIA sales. The jury found that the adviser and its representative failed to transparently disclose financial incentives when recommending FIAs over other investment products.
Specifically, the SEC asserted that the representative received approximately 7% commissions on FIA sales, significantly higher than the firm’s standard asset management fees (approximately 1.5% to 2.0%). Additionally, the representative recommended clients replace existing annuities prematurely, resulting in substantial surrender charges for clients and new commissions for the adviser—highlighting serious conflicts of interest.
This case serves as a critical reminder of the heightened scrutiny investment adviser firms face when their representatives sell insurance products like FIAs. Key risks include:
To protect against regulatory risks and fulfill fiduciary responsibilities, investment adviser firms should adopt rigorous disclosure and supervision practices, including:
Detailed Compensation Disclosures
Conflict Acknowledgement and Client Education
Firm-Level Compensation Reform
Robust FIA Sales Supervision
The recent SEC jury decision is a clear warning to all investment adviser firms involved in FIA sales. Adherence to robust disclosure practices, client acknowledgment of this conflict of interest, thoughtful compensation adjustments, and rigorous supervisory measures are essential to mitigate regulatory risks and uphold fiduciary duties.
Investment adviser firms must prioritize these practices proactively to protect clients, fulfill regulatory obligations, and maintain the integrity of their advisory relationships.
Conflicts of Interest – FP – Varying Compensation for Insurance/Securities – Client Acknowledgement
Conflicts of Interest – Fixed Indexed Annuities – Best Practices
WSP/CoE Section Update – Recommending FIA in lieu of SMA is Retirement Account
IAR CE: SEC Enforcement of Investment Adviser Recommending Fixed Indexed Annuities
The information contained in this post is general in nature intended for educational purposes only and is not a comprehensive analysis of this topic. This is merely a summary and does not necessarily include all material facts from the proceeding. The author has not verified the accuracy of the regulator’s press release or order and is not offering any opinion whether the allegations made by the securities regulator or the jury decision are accurate. This post is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s published guidance for more details about the topics referenced above. For more information about the limitations of this blog post and information on our website, please see our Disclosures webpage.
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]]>Under the new leadership of Acting Chair Mark Uyeda, the U.S. Securities and Exchange Commission (“SEC”) recently issued and settled a cease-and-desist order that serves as a stark reminder: an investment adviser’s fiduciary duty to act in client’s best interests remains the bedrock for an investment adviser.
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]]>While the order does not necessarily signal a change in the SEC’s enforcement approach, it underscores the fact that fundamental obligations – providing full disclosure of any conflicts of interest and only giving investment advice in the best interest of the client —still matter as much as ever, irrespective of who is at the helm.
Change of Account Type: From approximately June 2020 through October 2023, an investment adviser firm and one of its representatives allegedly failed to provide adequate fee disclosures when converting certain clients from brokerage accounts to investment advisory accounts.
Changed Fee Structure: The SEC asserted that these newly converted advisory accounts were charged fees based on a percentage of assets under management, rather than brokerage commissions. Given that many of the converted accounts had relatively minimal trading activity, the shift purportedly led to higher overall costs for clients.
Client Impact: According to the SEC, the clients allegedly did not receive additional services or benefits commensurate with this increase in costs. The Commission further stated that the adviser placed its own financial interests ahead of its clients by recommending the conversion.
Account Reviews: The SEC alleged that the investment adviser firm did not properly review the clients’ investment profiles or evaluate whether an advisory account was truly in their best interests.
Compliance Deficiencies: The investment adviser firm allegedly failed to provide Form ADV disclosure documents in a timely manner to many of the clients with converted accounts. The SEC also asserted that the investment adviser firm lacked the necessary controls and oversight, contributing to the alleged compliance violations.
Violation of Advisers Act: The SEC stated that the investment adviser firm violated Sections 204, 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rules 206(4)-7 and 204-3.
Cease-and-Desist & Monetary Penalties: The investment adviser firm must cease and desist from further violations of federal securities laws and pay a civil penalty of $150,000.
Independent Compliance Consultant: The investment adviser firm is required to retain an independent compliance consultant to evaluate its existing policies, procedures, and disclosures, and recommend enhancements to prevent future violations.
Representative’s Penalty: The investment adviser representative involved is suspended for 9 months and must pay a separate $75,000 penalty, underscoring the SEC’s commitment to holding both the firm and individual accountable for fiduciary breaches.
Client Notification: Additionally, the investment adviser firm must send a copy of the SEC’s order to all current and former clients, ensuring full transparency about the nature and resolution of the enforcement action.
Some industry observers have speculated whether a leadership change at the SEC might alter the Commission’s enforcement priorities. However, this order highlights the SEC’s continued focus on protecting retail investors and ensuring investment advisers uphold their fiduciary responsibilities. The message is clear: Acting in a client’s best interest is not optional. Under the SEC’s current leadership, advisers can expect rigorous scrutiny of disclosures, fee structures, and account type determinations.
Investment adviser firms looking to shore up their compliance programs should use this enforcement action as a roadmap for proactively identifying and fixing potential deficiencies. The following are few best practices that an investment adviser should consider.
Revisit Fee Structures: Examine whether advisory fees are aligned with the level of investment management and other services provided.
Enhance Disclosures: Ensure that all material facts, especially those concerning compensation, conflicts of interest, and fee arrangements, are clearly and timely disclosed to clients.
Conduct Account Type Reviews: To the extent that the investment adviser firm is dually registered as a broker-dealer or has investment adviser representatives licensed as registered representatives, perform ongoing assessments of account types, client profiles, and trading patterns to confirm that each client is served by the most appropriate account structure.
Strengthen Compliance Programs: Develop and regularly update written policies and procedures that specifically address fee arrangement disclosures, account type reviews, and timely delivery of Form ADV.
By placing the client’s interest at the forefront—through transparent cost structures, thorough evaluations of client needs, and robust disclosure practices – investment advisers can meet their fiduciary obligations and reduce the risk of future regulatory scrutiny.
WSP/CoE Section Update – Account Type Suitability (Commission vs. Fee)
Included with Annual Compliance Packages (Bronze, Silver, Gold, Platinum & Titanium) in our KnowledgeBase
Available on a la carte basis in our online store at https://www.ria-compliance-consultants.com/product/wsp-coe-section-update-account-type-suitability-commission-vs-fee/
Suitability – Broker-Dealer (Commission) v. RIA (Fee) Account – Client Acknowledgement
Included with Annual Compliance Packages (Bronze, Silver, Gold, Platinum & Titanium) in our KnowledgeBase
Available on a la carte basis in our online store at https://www.ria-compliance-consultants.com/product/suitability-broker-dealer-commission-v-ria-fee-account-client-acknowledgement/
The information contained in this blog post is general in nature intended for educational purposes only and is not a comprehensive analysis of this topic. This is merely a summary and does not necessarily include all material facts from the proceeding or order. RIA Compliance Consultants, Inc. has not verified the accuracy of the regulator’s press release or order and is not offering any opinion whether the allegations made by the securities regulator are accurate. This post is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s order, rules, and published guidance for more details about the topics referenced above. For more information about the limitations of this blog post and information on our website, please see our Disclosures webpage.
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]]>As we move into 2025, it is crucial for investment adviser firms to stay on top of their regulatory obligations, particularly the requirement to file Form 13F. This filing is mandated by the U.S. Securities and Exchange Commission (SEC) for investment adviser firms which exercise investment discretion over $100 million or more in Section 13(f) securities as of the last trading day of any month during the past calendar year.
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]]>In order to determine whether your investment adviser firm had discretion over $100 million or more of 13(f) securities on the last trading day of any month during the past calendar year, here’s a link to the current list of 13(f) securities at the website of the SEC. Form 13F must be filed within 45 days of the end of the calendar year when the threshold was reached, and three subsequent reports are required to be filed within 45 days of the end of the first three calendar quarters of the year.
The SEC has updated the filing deadlines for Form 13F for the calendar year 2025. Here are the key dates to remember:
Q4 2024: February 14, 2025
Q1 2025: May 15, 2025
Q2 2025: August 14, 2025
Q3 2025: November 14, 2025
Q4 2025: February 14, 2026
Failure to file Form 13F on time can result in significant penalties. The SEC has been vigilant in enforcing these requirements, as evidenced by recent fines imposed on firms for non-compliance. It is essential to ensure that your filings are accurate and submitted by the deadlines to avoid any regulatory issues.
If your investment adviser firm is an existing client of RIA Compliance Consultants, Inc. and needs assistance with preparing the Form 13F, please contact our Consulting Team for guidance. If your investment adviser firm does not currently work with us, please call our Business Development Team at 877-345-4034 for an introductory call to learn more about services.
SEC Fines Investment Adviser for Failure to File Form 13F
FAQs: Form 13F, Form SH, Schedule 13D & Schedule 13G
SEC Proposed Changes to Form 13F for Institutional Investment Managers (8/3/2020)
SEC’s Deadlines for Filing Form 13F in 2015 (1/4/2015)
Deadline Approaching for Filing the Form 13F with the SEC (1/12/2015)
SEC Settles a Form 13F Filing Violation for a $100,000 Penalty (8/16/2007)
This regulatory alert is a brief summary which is general in nature and offered only for educational purposes. It should not be considered as a comprehensive review or analysis of this obligation. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
RIA Compliance Consultants, Inc. is not a law firm and does not provide legal services. This communication is not legal advice. An investment adviser firm which has failed to file Form 13F in accordance with the Securities and Exchange Act of 1934 should immediately consult with qualified legal counsel about self-disclosing such violations to the SEC.
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]]>Most jurisdictions participate in the IARD Automatic Failure to Renew Program. If your investment adviser firm or its representatives are registered or notice filed in a jurisdiction that participates in the IARD Automatic Failure to Renew Program, your jurisdiction has authorized FINRA to automatically terminate your investment adviser firm and investment adviser representative registrations on December 31, 2024, if your investment adviser firm’s IARD Renewal Account is not funded by the renewal deadline.
Unfortunately, every year there are investment adviser firms that fail to submit renewal fees through their IARD accounts in a timely fashion, and almost all state securities regulators will automatically terminate these registered investment adviser firms and their investment adviser representatives for failing to pay their renewal fees. Contacting each state securities regulator after such a failure to renew can be time intensive and potentially expensive since a state securities regulator typically has the authority to require a new registration application and prohibit the charging of investment advisory fees as long as the investment adviser and its representatives are unregistered.
To help avoid problems with your investment adviser’s annual renewals, RIA Compliance Consultants recommends that you utilize our IARD Renewal Program and ADV Annual Amendment Service. For only $1,325*, investment advisers that engage us by executing the engagement and remitting the retainer fee by November 29, 2024, will receive assistance with the annual renewal process and with preparing and submitting the Form ADV Part 1 Annual Amendment that all investment advisers are required to file and submit within 90 days following the investment adviser’s fiscal year.
Engagement of RCC after November 29, 2024 will be subject to availability and additional fees will be charged.
Before you make the online purchase you will be prompted to sign an engagement agreement for these services. Please keep in mind that we must receive the retainer payment and executed engagement agreement by November 29, 2024 in order to receive the $1,325 rate.
If you would like to discuss these services, contact your support person or our business development team at BizDevTeam@ria-compliance-consultants.com.
*NOTE: The above link is not intended for an investment adviser firm managing or advising private fund(s) or a firm which is an Exempt Reporting Adviser (“ERA”); such firms are subject to different fee schedules for our IARD Renewal and ADV Annual Amendment Services. If your firm is registered as an investment adviser and manages or advises one or more private funds, please click here to sign up for our service. If your firm is an Exempt Reporting Adviser, please click here to sign up for our services.
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