Renewal Reminder for 2008
If you have not yet received any renewal information from FINRA (formerly the NASD) for your investment adviser registration it is available at www.iard.com/pdf/renewal_bulletin.pdf*. Any questions regarding the renewal process can be directed to the IARD Help Desk at 240-386-4848. Preliminary Renewal Statements were made available on November 5, 2007. If you plan on terminating any registrations at the end of the year you can currently file Form ADV-W’s (to terminate the firm) and Form U5’s (to terminate investment adviser representatives) post-dated to December 31, 2007.
The fee waivers instituted by the Securities and Exchange Commission, FINRA and the states collectively through the North American Securities Administrators Association are still in place for 2008 renewals. Therefore, if you are registered only in the State of Washington the fee for the firm will be $75 ($75 Washington renewal fee, IARD processing fee is waived), and $50 for each investment adviser representative ($20 Washington renewal fee and $30 IARD processing fee). If you are also registered in other states additional renewal fees will apply, so you will need to review your renewal statement in detail.
This year, if the firm has no funds credited to its Renewal Account, but has sufficient funds available in its Daily Account as of December 10th to pay the Preliminary Renewal Statement in full, FINRA will sweep the renewal payment from the Daily Account on the 10th.
You have the option of paying by check, wire transfer, or e-pay. The payment instructions can be accessed in the renewal bulletin referenced above. If you use e-pay after December 6th (it takes FINRA several days to post the funds to your account), please ensure that the funds are properly credited to your Renewal Account.
The final day for FINRA to post funds to your renewal account is Friday, December 21st, so please ensure that your payment arrives several days ahead of that deadline to give FINRA adequate time to process the transaction.
Remember to pay the full amount of the Preliminary Renewal Statement. If there are errors, call the Help Desk to straighten them out, and corrections will be made on the Final Renewal Statement that will be available on January 2, 2008. Any additions/deletions of states or representatives that occurred after November 2nd and prior to CRD shutdown on December 21st will also be reflected on the Final Renewal Statement. Even if you have no changes, it is a good idea to review the Final Renewal Statement to ensure that no errors have occurred.
Business Continuity Plans
The State of Washington has not mandated that investment advisers registered with the Division adopt and test business continuity plans, unlike FINRA for its member broker-dealers and the SEC for the federally registered investment advisers. Nevertheless, the Division strongly encourages advisers to adopt (and test!) contingency plans to deal with situations where key persons of the adviser are unable to perform their duties for extended periods of time, whether due to personal issues or calamitous situations. Here are several websites to get you started:
The State of Washington’s Emergency Management Division recently developed a portal for businesses at: http://www.emd.wa.gov/preparedness/prep_business.shtml. It contains comprehensive information and links to other databases.
Another source of information is FINRA. Its comprehensive index is available at: http://www.finra.org/RulesRegulation/IssueCenter/BusinessContinuityPlanning/index.htm
Also, the federal Small Business Administration has a website devoted to disaster preparedness at: http://www.sba.gov/services/disasterassistance/disasterpreparedness/index.html
* This document is a PDF file, and you will need Adobe Acrobat Reader to view it. If you don't already have Acrobat Reader installed on your computer, you may download it for free from Adobe.
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