SEC Annual Updating Reminder

A brief reminder for those firms that are registered with the U.S. Securities and Exchange Commission (“SEC”) that they need to submit an annual updating statement within 90 days of the end of their financial year.

With this in mind, those firms whose year end is 31 December 2014 must submit to the SEC by 31 March 2015 its annual updating amendment for 2014, as follows:

  • Exempt Reporting Advisers: Form ADV Part 1A
  • Investment Advisers: Form ADV Part 1A and 2A (Brochure).

These documents must be filed electronically with the SEC via the FINRA Investment Adviser Registration Depository (“IARD”), and will be publicly available on-line shortly after submission. Before uploading these documents, it is recommended that you consult the balance in each registered entity’s FINRA Flex Funding Account so as to ensure there is sufficient cash available for payment of the required annual fees, as follows:


Registration / Assets Under Management IARD Annual Fee
Investment Adviser Under USD 25 Million USD 40
Investment Adviser USD 25 Million – USD 100 Million USD 150
Investment Adviser Over USD 100 Million USD 225
SEC Exempt Reporting Adviser USD 150


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