IARD

Has anyone out there gotten used to calling the NASD “FINRA” yet? IM Insight certainly hasnt. While were all getting used to the new name, here are a few things that advisers should attend to:First off, the IARD and CRD systems website addresses have been renamed. IARD: https://crd.finra.org/iadWeb CRD: https://crd.finra.orgThe old addresses will still work, […]

The Investment Adviser Association and National Regulatory Services have issued their seventh annual “Evolution/Revolution” report, which profiles the investment adviser profession based on IARD data. According to the report, 732 hedge fund advisers withdrew their SEC registrations over the past year. As of April 6, 2007, there were a total of 10,446 SEC-registered advisers, managing […]

As noted in last weeks IM Insight, the IARD system is now accepting the electronic filing of Form ADV Part II. The SEC staff has updated its Q&A on IARD to confirm that it has not changed the Part II filing requirements for SEC-registered advisers: “SEC rules require advisers to maintain Part II and amendments […]

Its official: The IARD system is now accepting Part IIs.As of the end of last week, over two dozen firms – both SEC and state-registered advisers – had filed Part II on IARD. At this point, filing Part II (or a narrative brochure in lieu of Part II) is completely voluntary. SEC-registered advisers are not […]

Advisers soon will have the opportunity to file their existing Form ADV Part IIs on IARD, for all the world to see. According to Maryland Securities Commissioner Melanie Senter Lubin, who chairs the North American Securities Administrators Associations CRD/IARD steering committee, state securities regulators are planning a new pilot program in which hundreds of state-registered […]

According to SEC associate director Robert Plaze, 259 hedge fund advisers have withdrawn their registration due to the Goldstein decision. Speaking at last weeks ALI-ABA conference, Plaze reported that there currently are 10,483 advisers registered with the SEC. Of those, 2,256 (22 percent) are hedge fund advisers. Putting those 259 post-Goldstein deregistrations into context, Plaze […]

Beginning this week, firms can access their “Preliminary Renewal Statements” on IARD. For more information on IARD renewals, see the 2007 IARD Renewal Program Bulletin.“Make sure that you get the fees deposited by the deadline,” warned ACA consultant Rhea Shelton, a former state regulator. If the deadline is not met, the entire filing must be […]

The SEC and the North American Securities Administrators Association have extended the waiver of annual IARD fees for another two years. For firms with $100 million or more in assets under management, thats a savings of $550 per year. In addition, the SEC and NASAA will waive initial IARD set-up fees for new advisers until […]

As it does every year, the NASD has posted a Notice to Members providing guidance and key dates for the upcoming IARD/CRD renewal season. See NTM 06-59. 

As soon as the court issues its mandate in the Goldstein v. SEC case, Advisers Act Rule 203(b)(3)-1 will revert back to its pre-hedge fund rule status. Which means that the definition of “private fund” will officially disappear. But that wont make the references to “private fund” on Form ADV magically disappear at the same […]