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Adviser Compliance for 2013, Part III: Make Sure Your IARD Account Is Funded

investment adviser complianceBefore you submit your annual ADV updating amendment, the Investment Adviser Registration Depository (IARD) requires that a firm have enough funds deposited in its Daily Account to cover the fees associated with the filing. It is advisable for registered advisers not to wait until the last minute to fund the IARD account.  Here are some technical pointers—more information can be found at IARD.com.

Fees are charged based on your firm’s regulatory assets under management as per your Form ADV.

  • $100 million or more: Filing fee of $225
  • $25 million to $100 million: Filing fee of $150
  • Less than $25 million: Filing fee of $40
  • Exempt Reporting Advisers: Filing fee of $150

Be aware that the system may not always be available when you need it.  IARD is available from 7 a.m. to 11 p.m., Eastern Time (ET), Monday through Friday.  IARD is not available on holidays in which FINRA is closed and is not available after 6 p.m., ET, on the business day immediately preceding some holidays. In addition, weekend availability may vary due to software drops and monthly maintenance.  It is worth checking.

There are four methods for funding your account:

  • Check or money order (please note that there is time lag for depositing checks and plan accordingly)
  • Wire payments
  • Web CRD/IARD E-Pay
  • Transfer from an affiliated firm or transfers between Daily or Renewal Accounts.

If mailing your payment via USPS, the address is:

FINRA

P.O. BOX 7777-W9995

Philadelphia, PA 19175-9995

For express delivery, courier, and overnight mail, the following address must be used:

FINRA

Attn: 9995

500 Ross Street 154-0455

Pittsburg, PA 15262

Please also note that the address for Daily Account payments is different from the address for funding your firm’s Renewal Account.

For wire payments, instruct your bank to contact Mellon Financial, Philadelphia, PA. You will need to provide your bank with the following information to initiate the transfer:

  • ABA Number: 031 000 037
  • Beneficiary: FINRA
  • FINRA Account Number: 8-234-353
  • Reference Number: Firm CRD/IARD Number

Remember to inform your bank that funds are to be credited to the FINRA bank account and to use your firm’s CRD number as a reference only. Also remember to record your confirmation number, as you will need it to verify the funds have been credited to your account. If you send your wire transfer by 2:00 p.m. ET, you firm may confirm receipt of the wire payment by FINRA the next business day by checking your Daily Account online or calling the IARD hotline at (240) 386-4848.

Eckerle Law offers legal advice in a variety of transactional and regulatory matters serving your business law needs. If your company would like to strengthen its business practices, please contact us today so we can leverage our experience to create real-life business and legal solutions to help your business thrive.