Once the Account Administrator(s) and the firm's users have been entitled to IARD, your firm should:
- Send funds to your firm's FINRA Flex-Funding Account (CRD/IARD Daily Account).
- Funds must be on deposit in your Flex-Funding Account before you can submit your first electronic Form ADV.
- Required funds should cover your firm’s IARD Initial Set-Up Fee and any fees associated with new state Notice Filings or state registrations.
- Once your firm has registered electronically, determine whether you will be registering your firm’s IA representatives and be sure to deposit funds to cover your IA representatives' Initial Set-Up Fees and any applicable registration fees.
- View additional information regarding IARD Fees and Accounting.
- Determine the appropriate Form ADV filing type to register your firm.
- Logon to IARD and begin creating your electronic Form ADV. When creating your electronic Form ADV, you should be aware of the following tips:
- In order to assist in creating your first electronic Form ADV, these filings can be saved in draft form as a “pending” filing for a period of 120 calendar days in the IARD system.
- The "pending" Form ADV filing can only be accessed by entitled users at your firm and cannot be viewed by either FINRA or the applicable regulators until after they are officially submitted.
- If the "pending" Form ADV filing is not submitted after 120 days, the system will automatically delete it.
- When you have completed your Form ADV be sure to run the IARD system's "Completeness Checks" to identify any problems with the filing data.
- Correct any errors or omissions that the "Completeness Checks" alert you of before you submit the filing.
- Once your filing has passed the "Completeness Checks," you may submit your electronic Form ADV.
- Logon to IARD and begin creating your electronic Form ADV. When creating your electronic Form ADV, you should be aware of the following tips:
- The SEC and/or jurisdictions will review your firm’s filings.
- The SEC effective date is already captured in the system as part of FINRA's initial set-up processing.
- The SEC and jurisdictions will review your electronic Form ADV and will communicate directly with you about any deficiencies they may find in their review process.
- Determine the appropriate filings to register your firm’s IA representatives.
- IA firms should register their IA representatives electronically on Web CRD as directed/mandated by states/jurisdictions; additionally, firms may voluntarily register their IA representatives via Web CRD as all of the states/jurisdictions will accept these electronic form filings for IA representatives.
- Form U4: Be sure to understand which Form U4 filing type should be your IA representative’s first electronic Form U4.
- Continue to maintain your firm and/or IA representatives’ filings with future electronic filings.
- Make all future amendments to Form ADV via IARD.
- SEC-filing firms must file their Annual Amendment within 90 days following the end of their fiscal year. The Annual IARD System Fee will be charged when firms file their Annual Amendment.
- State-filing firms may also be required to file an Annual Amendment; however, the Annual IARD System Fees will be charged during the December Renewal period when state filing fees for the new year are collected by FINRA and dispersed to the appropriate states.
- Make all future amendments to Form U4 via Web CRD.
- Remember to ensure your firm's Flex-Funding Account has sufficient funds on deposit to cover system processing fees and any applicable filing fees.
- The IARD annual Renewal Program will begin in November of each year to renew the registration of your firm and/or IA representatives with states/jurisdictions for the following year.
- Make all future amendments to Form ADV via IARD.