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Key Deadlines and What Advisers Need to Do
Registered investment advisers should review their 2027 Investment Adviser Registration Depository (IARD) renewal obligations now and ensure full payment posts to their Renewal Account by December 7, 2026. Coordinating funding and year-end filings can help avoid registration disruptions and delays to annual filings.
Renewal Funding and Payment Deadlines
Preliminary Renewal Statements are available through E-Bill in FINRA Gateway. Firms should review their statements and allow time for payment processing. FINRA recommends submitting electronic payments by December 2, 2026, to allow time for the full payment to be credited by December 7.
Beginning December 7, FINRA will automatically transfer available funds from a firm’s Flex-Funding Account to its Renewal Account when the account balance covers the total renewal fees due. Transfers continue through December 27. Firms should verify that payment has been posted rather than relying solely on an available account balance.
Year-End Filing and Reconciliation Dates
The final day to submit registration filings before year-end processing is December 27, 2026. IARD and the Central Registration Depository (CRD) will be available from 10:00 a.m.- 6:00 p.m. ET on December 27. Submissions received after the processing cutoff will be queued, with processing scheduled to resume January 2, 2027, at 8:00 a.m. ET.
Final Renewal Statements will be available January 2, 2027. Firms should reconcile the final assessment against the preliminary payment and pay any additional amount owed by January 22, 2027.
What Advisers Should Do Now
- Review the Preliminary Renewal Statement and confirm all intended registrations and notice filings are included.
- Arrange payment early and verify that the full renewal amount posts by December 7.
- Consider maintaining sufficient funds in the Flex-Funding Account for anticipated Form ADV annual updating amendment fees, applicable state registration or notice-filing fees, and Form PF filing fees. Advance funding can help avoid delays when annual filings are ready.
- Schedule time-sensitive registration filings before the December 27 processing cutoff and assign responsibility for reviewing the Final Renewal Statement in January
How ACA Can Help
ACA can help firms navigate registration and notice-filing requirements, prepare Form ADV and Form PF filings, and plan for year-end compliance obligations.
Contact your ACA consultant or the ACA team to discuss your renewal and annual filing needs.