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News January 18, 2010 Issue

They’re Back – IARD Renewal Fees Are Due

Itís time to pay up.

FINRA posted Final Renewal Statements and reports on its web site on January 4 that represent the final status of adviser and adviser representative registrations and/or notice filings as of the end of the 2009 calendar year.

If you havenít already checked yours out, now is the time. Final renewal fees, if you owe them, are due February 5.

Itís been a while since IARD fees have been assessed. At FINRAís recommendation, the SEC has waived them since 2006. Years of surpluses in the system have been calculated to be exhausted, however, at some point in 2011. As a result, FINRA recommended resumption of the fee assessments at a reduced rate.

To help firms and adviser representatives "review, reconcile and respond" to their statements and reports, FINRA has issued guidance in Regulatory Notice 10-02. FINRA, of course, oversees the Investment Adviser Registration Depository, a function delegated to it by the SEC years ago.

Renewal reports include all individual registrations renewed for 2010, but not any registrations that were "pending approval" or "deficient" at the end of 2009. Firm renewal reports include a listing of renewed personnel, and similarly exclude pending approval or deficient personnel registrations. For branches, "firms should use this report to reconcile their records for renewal purposes."

Reviewing and reconciling the reports is as important as determining whether you owe a fee. Any discrepancies between a firm or individualís records and the FINRA report must be reported to FINRA by the February 5 payment deadline.