Renew, then Relax
Can you believe it's November already? In some respects, 2020 seems to have been the longest year EVER, and yet, I can't believe how fast it has flown. With the Thanksgiving holiday approaching, the month of November makes me reflect on gratitude. I want to take this opportunity to thank you for being a valued client. I hope you know how much I appreciate the opportunity to work with you! The last two months of the year are usually hectic with trying to juggle the demands of the holidays along with your usual work and family obligations. Here are just a couple of quick reminders of some important compliance tasks coming up, so you don't forget. IARD Renewals The SEC recently published its 2021 IARD Renewal Calendar. Some important dates to remember:
November 14 - Preliminary Statements will be available on the IARD E-Bill page. Be sure to log in to your IARD account to retrieve your Preliminary Statement and verify the accuracy of the charges. (If I have a user account on your IARD account, I will retrieve your statement for you, review the statement, and contact you to arrange for payment of the fees.)
December 14 - Deadline for submitting your fees for the Preliminary Statement to your Flex-Funding account. I recommend that fees be submitted a couple of days ahead of this deadline as it can sometimes take a day or two for funds to settle in your account.
January 2 - Final Statements will be available. Like the Preliminary Statement, you should log in to your IARD account to retrieve the Final Statement. Unless you've had changes in your firm or IAR registrations since the Preliminary Statement was issued, there typically won't be any additional charges on your final statement. If there are, submit the necessary fees to your IARD Flex-Funding Account. (Again, if I have a user account on your IARD account, I will take care of this for you.)
January 22 - Deadline for submitting any remaining fees due on the Final statement to your Flex-Funding Account.
Note that the IARD will be unavailable on November 14, December 27, and January 1 due to the renewals processing. Annual ADV Updates RIAs are required to submit an annual amendment to their Form ADV Part 1 within 90 days of their fiscal year end. For most firms, the fiscal year end is December 31, which means that the annual update is due March 30, 2021. If you find some spare time in your schedule, you might want to get a jump on beginning to review your Form ADV Part 2A and 2B and your Form CRS (if SEC-registered). You may also want to consider the data that will need to be compiled for the Part 1 update (AUM, number of clients, number of accounts, etc.), and make sure the data is easily retrievable as of December 31. Note any changes that need to be made to these documents during the first quarter of next year. SEC-registered firms also need to pay the SEC annual amendment fee before filing the Form ADV Part 1 update. For RIA firms with AUM over $100 million, the annual filing fee is $225. Between $25 million and $100 million, the fee is $150, and under $25 million, the fee is $40. You may want to include these fees when you are adding your renewal fees to your Flex-Funding Account, so you don't forget later. You don't want to miss your Part 1 annual update filing deadline because the fees aren't in your account! Thanksgiving Take time this month to enjoy your holiday, and spend time with your family and friends wherever and however possible. (Zoom virtual turkey dinner, anyone?) This year has been a rough one in many ways, but take time to focus on the bright spots and reflect on things for which you're grateful. Aside from my wonderful clients, I'm also grateful for:
Technology that allows us to stay in contact, and to work, learn, play, and shop from the comfort and safety of our homes.
A husband who didn't drive me insane, even after spending literally every moment together for months.
More time to spend working in the garden and taking long walks, since our travel plans were shelved for the year.
Taking time to slow down, re-examine my priorities and how I spend my time.
I send wishes for a very Happy Thanksgiving to you and yours. As always, let me know if you have any questions. Happy to help!