This material is provided for general informational purposes and does not constitute legal or accounting advice, nor does it set a new policy, nor does it represent the views of any specific NASAA member jurisdictions. Information has been summarized and paraphrased for educational purposes. Information on this page is as of the date noted. If reproduced, the contents of this page should not be modified without express written permission.
Last updated: August 1, 2019
What is an ADV and how is it used?
The Form ADV is the uniform form used by investment advisers to register with both the Securities and Exchange Commission (SEC) and state securities regulators. Form ADV stands for the Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers. The form is divided into a Part 1 and Part 2, with additional subparts. More information is available here.
- Part 1A must be completed by any investment adviser seeking registration with the SEC or any state securities regulator. This part solicits information about the investment adviser’s business, its ownership structure and business practices, and its key employees and client information. Part 1 also requires the adviser to disclose any disciplinary events involving the advisory firm and its affiliates.
- Part 1B is required by state securities regulators and includes additional disclosures about the firm’s disciplinary history and other practices.
- Part 2A is specific to the firm and requires the investment adviser to prepare a narrative, explaining in plain English, disclosures about the adviser’s business practices, services offered, fees, conflicts of interest, and disciplinary information. Part 2A is generally referred to as the adviser’s “brochure”.
- The Part 2B is specific to supervised persons working on behalf of the firm. This part requires a plain English narrative regarding the supervised person’s educational background and work experience, disciplinary background, other business activities, compensation and supervision. The Part 2B is commonly referred to as the “brochure supplement.”
What is IARD?
The Investment Adviser Registration Depository (IARD) is an electronic filing system for Investment Advisers sponsored by the SEC and North American Securities Administrators Association (NASAA), with the Financial Industry Regulatory Authority (FINRA) serving as the operator of the system. The IARD system collects and maintains the registration, reporting and disclosure information for investment advisers and their associated persons. The IARD system supports electronic filing of the current Forms ADV and ADV-W; is a centralized repository for fee and form processing; provides for regulatory review of filings; facilitates the annual registration renewal process; and supports public disclosure of investment adviser information.
How do I get to IARD?
Once an investment adviser firm completes the entitlement process, it will obtain access to the IARD system. The entitlement process is needed in order to register as an investment adviser or file as an exempt reporting adviser via the IARD system. To obtain entitlement to the IARD system, firms must request access to IARD/Web CRD by completing and submitting the New Organization SAA Entitlement Form and completing the entitlement process. Details. For firm’s that are already entitled to the IARD system,click here.
Where do I call if I need help with the IARD system?
Questions related to the IARD system, including entitlement, navigation, fees, usage and filing should be directed to the IARD Call Center at (240) 386-4848.
Are there fees associated with using IARD?
Yes. System fees are assessed for the electronic filing of forms required for investment adviser firm registration on the IARD system. Whether filing as an SEC registrant, state registrant, or exempt reporting adviser, the initial set-up fee is charged at the time the firm makes its first electronic Form ADV submission into the IARD system. An annual fee is also assessed for both SEC and state filers.
The SEC assesses its annual system fee at the time the firm submits its Annual Amendment, which is due within 90 days following the end of the firm’s fiscal year. For state registrants, the annual system fee is assessed at the time that the annual renewal fees are collected.
Initial and/or annual fees may be waived for a given year as determined by NASAA on an annual basis. Current fees may be viewed in the fee table, here. In addition to system processing fees, investment advisers may also be assessed jurisdiction-related application, amendment and renewal fees for the firm, branches and representatives.
Do I have to wait until the end of the year to complete my Annual Update Amendment?
The Annual Update Amendment may not be submitted prior to the Adviser’s fiscal year end. However, investment adviser’s may create their annual amendment 60 days prior to their fiscal year end, and it can be maintained in the IARD system during this time as a “pending” filing.
Where do I find information about my annual renewal requirement?
As part of its operation of the IARD system, FINRA facilitates the collection of renewal fees through the IARD. Renewal specific information including schedules, fee tables and frequently asked questions may be found at IARD.com under the Renewal Program link, here.
Can you only have one Account Administrator with your IARD account?
Firms may have only one Super Account Administrator (SAA) but may have more than one Account Administrator (AA). SAAs can create Account Administrators (AA) who are authorized to manage entitlement for other users within the organization. Both SAAs and AAs can create, delete and maintain user accounts. SAAs are the primary point of contact for the investment adviser’s entitlement within the firm.
Do any States require you to submit your ADV in paper to them?
No. The Form ADV (Paper Version) may only be submitted to the SEC or a state regulator in paper if the firm has been granted a hardship exemption. See Form instructions for further guidance. Otherwise, the SEC and all state regulators require the submission of the Form ADV electronically through the IARD system.
Does IARD work in all browser types?
IARD will work using the following browsers: Chrome, Firefox, Internet Explorer and Safari. However, IARD will only support newer versions of web browsers to securely transmit information over the internet. If your current browser does not meet or exceed the minimum browser requirements, you must upgrade your browser. Details are available here.
Can you access IARD 24 hours a day?
No. IARD is typically available Monday through Friday from 5 a.m. to 11 p.m., Eastern Time (ET). The IARD also has limited availability on the weekends. The hours are generally 8 a.m. to 6 p.m., ET on Saturday and 10 a.m. to 6 p.m., ET on Sunday.
What do I do if I forget my IARD username or password?
A user who forgets his/her username can contact their firm’s Super Account Administrator or any firm designated Account Administrator to obtain this information. If a user forgets his/her password, he/she can click on the Forgot Password? link on the login screen to request a new password. The user must know the appropriate security responses to take advantage of this functionality.
What is the difference between CRD and IARD?
The Central Registration Depository (CRD) system was developed as a joint initiative by NASAA and NASD (now FINRA), in 1981. The CRD system was developed to consolidate multiple paper-based licensing and regulatory processes into a single, nationwide computer system. The system made it possible to complete and submit a single application filing to multiple jurisdictions. It streamlined the registration process and maintains registration, qualification and disclosure histories for securities firms and professionals.
The IARD system was developed jointly by NASAA and the SEC and built and operated by FINRA. It is an electronic filing system for investment advisers, like CRD, utilized to promote uniformity, using common forms, and efficiency through a paperless environment. The IARD system collects and maintains the registration, qualification and disclosure information for investment adviser firms and their representatives.
How do I locate the contact information for my home-state to discuss my filing with them?
NASAA’s website serves as a resource for industry and regulators alike. The contact information for each NASAA jurisdiction is available here.