Preparing for Preliminary Renewal Reports

Time to prepare for the 2017 Renewals.  The Preliminary Renewal Statement will be ready for viewing on Monday, November 14th.   You may want to confirm that the states in which you are registered or noticed filed (if you are an SEC registered adviser) are correct. The reports will be run tomorrow, so the IARD site will not be available.

The first step in the process is to run a report of clients by state.  Are you under the de minimis in any states where you are currently registered or notice filed?  If so, you may want to update your filing via the IARD.  Otherwise, when the IARD prepares your Preliminary Renewal Statement over the weekend, you will see that state(s) on our statement.  You will then pay the 2017 fee for that state.

If you are notice filed, then it is probably wise to remove that state until you are once again required to file.  No sense paying for a notice filing when it is so easy to file when required to do so.

However, if you are state registered, you will want to determine if you will be going over the de minimis again soon.  It is typically a process to register in a state, so don’t remove the registration without considering this as part of your decision.

As a reminder, the de minimis as a state-registered adviser is six for every state except Texas and Louisiana where the de minimis is one.  For SEC registered advisers, the de minimis is 6 for every state except Texas, Louisiana, New Hampshire and Nebraska in which the de minimis is one.

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1 Response to Preparing for Preliminary Renewal Reports

  1. Great reminder, Cindi! And I didn’t know the de minimus rules had changed, or else I had them wrong to begin with. Great info as always. You provide a great public service with your blog.

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