The Investment Adviser Registration Depository, known as the IARD, is the electronic system that investment advisers use to register with the U.S. Securities and Exchange Commission and state securities regulators, file Form ADV, and pay their registration and renewal fees. It was developed jointly by the SEC and the North American Securities Administrators Association (NASAA) and is operated by FINRA. Every routine regulatory interaction an advisory firm has with its regulators, from initial application to annual renewal, flows through this single portal.
Who Files Through the IARD
The IARD serves both SEC-registered and state-registered investment advisers, and which regulator you answer to depends on assets under management.
- Under $25 million AUM: register with your state securities authority. SEC registration is prohibited if your home state regulates advisers, which every state except Wyoming currently does.
- $25 million to $100 million AUM: generally state registration, with exceptions for firms based in New York or Wyoming (which must register with the SEC) and for firms in states that don’t require registration.
- $100 million AUM and above: you may register with the SEC at $100 million, must register once you reach $110 million, and don’t need to withdraw from SEC registration until you fall below $90 million.
The distinction matters because state-registered advisers complete additional sections of Form ADV, pay different fees, and can face different disclosure rules than SEC-registered firms.1U.S. Securities and Exchange Commission. Transition of Mid-Sized Investment Advisers
Not every firm on the system is fully registered. Exempt reporting advisers (ERAs) rely on registration exemptions but still report to the SEC or state regulators through the IARD, filing a lighter version of Form ADV covering only Items 1, 2, 3, 6, 7, 10, and 11 of Part 1A plus corresponding schedules.2U.S. Securities and Exchange Commission. Form ADV – General Instructions
Getting Access to the System
Before a firm can file anything, it has to go through the FINRA Entitlement Program. The firm designates a Super Account Administrator by submitting a New Organization SAA Agreement. Once FINRA verifies the firm’s identity, it issues login credentials and an organization CRD number that becomes the firm’s permanent identifier across the system. The SAA can then create and manage user accounts for everyone who needs to file on the firm’s behalf.3IARD. How to Access IARD
Firms that later need to replace their SAA can do so through FINRA’s Account Management System. The replacement request must be approved by the firm’s Authorized Signatory, which for investment advisers is the Chief Compliance Officer or Additional Regulatory Contact listed on the current Form ADV.4FINRA. Super Account Administrator (SAA)
What You File: Form ADV
Form ADV is the core document filed through the IARD. It works as both the registration application and the ongoing disclosure that regulators and the public rely on. Which parts you complete depends on your registration status.2U.S. Securities and Exchange Commission. Form ADV – General Instructions
Part 1A
Part 1A collects operational information: ownership structure, direct owners and executive officers (Schedules A and B), assets under management, types of clients, compensation methods, affiliations with other financial entities, websites, and social media accounts. Item 11 covers disciplinary history.
Part 1B
Firms registering with one or more state securities authorities also complete Part 1B, which asks for information states care about but the SEC does not: bond and minimum capital requirements, unsatisfied judgments or liens, arbitration claims exceeding $2,500, and other business activities. Sole proprietors face additional questions about examination status (Series 65 or Series 66) and professional designations.
Part 2A: The Firm Brochure
Part 2A is a plain-English narrative describing your investment strategies, fee structures, and potential conflicts of interest. It reads like a client-facing document because it is one. You must deliver it to prospective clients before or at the time you enter into an advisory contract, and offer an updated version to existing clients annually within 120 days of your fiscal year-end when there have been material changes.5eCFR. 17 CFR 275.204-3 – Delivery of Brochures and Brochure Supplements
Part 3: Form CRS
SEC-registered advisers who serve retail investors must also file Form CRS, a brief relationship summary capped at two pages for standalone advisers or four pages for firms that are also registered broker-dealers. It covers services, fees, conflicts, and disciplinary history, and is filed electronically through the IARD.6eCFR. 17 CFR 275.203-1 – Application for Investment Adviser Registration
Fees and Funding Your Account
SEC Rule 203-1 requires investment advisers to file Form ADV electronically through the IARD, with limited hardship exemptions.6eCFR. 17 CFR 275.203-1 – Application for Investment Adviser Registration Fees are pulled automatically from a Flex-Funding Account you keep loaded in advance. You can fund it through the E-Bill system (ACH or wire), by direct wire or ACH to FINRA, or by mailing a check payable to FINRA with your CRD number on the memo line. Wire transfers received before 2 p.m. ET typically post the next business day; ACH transfers take several days longer.7IARD. Investment Adviser Accounting and Payment Methods
For SEC-registered firms, IARD system processing fees are tied to assets under management:
- Under $25 million AUM: $40 initial setup and $40 annual
- $25 million to $100 million AUM: $150 initial and $150 annual
- Over $100 million AUM: $225 initial and $225 annual
State-registered firms currently pay no IARD system processing fees; both the initial setup and annual fee are waived. SEC exempt reporting advisers pay $150 for both initial setup and annual fee, while state ERAs currently pay nothing.8IARD. IARD Firm System Processing Fees
State registration fees are separate and vary widely, running from $40 in some states to over $300 in others for both initial registration and annual renewal. A firm registered in multiple states pays each state’s fee individually.9Investment Adviser Registration Depository (IARD). Investment Adviser Fees and Settings Schedule
Annual Amendments and the December Renewal Cycle
Registration is not a one-time event. Every registered adviser must file an annual updating amendment within 90 days after fiscal year-end, updating responses to all items in Parts 1A and 1B (if applicable), Parts 2A and 2B, and all corresponding schedules. Form CRS must be updated within 30 days whenever information becomes materially inaccurate.2U.S. Securities and Exchange Commission. Form ADV – General Instructions
Material changes between annual cycles trigger other-than-annual amendments, which must be filed “promptly.” Common triggers include a new principal office address, ownership changes, and new disciplinary events. ERAs face the same 90-day annual deadline and must file prompt amendments when information in Items 1, 3, or 11 becomes inaccurate, or when Item 10 information becomes materially inaccurate.2U.S. Securities and Exchange Commission. Form ADV – General Instructions
The annual renewal program runs on a fixed calendar. For the 2026 cycle, preliminary renewal statements become available in early November through E-Bill. Payment on the preliminary statement is due in early December, and firms with sufficient funds in their Flex-Funding Account have renewal fees transferred automatically. The final statement payment deadline falls in late January of the following year.10Investment Adviser Registration Depository (IARD). 2026 Renewal Program Calendar
What Happens If You Miss a Deadline
The SEC does not offer a grace period for late annual updating amendments. Missing the 90-day deadline puts the adviser in violation of Rule 204-1, and whether that draws enforcement depends on the facts. SEC staff recommends that a late filer include a note in the “Miscellaneous” section of Schedule D explaining the situation, and keep internal records of what happened and what the firm is doing to prevent a repeat.11U.S. Securities and Exchange Commission. Frequently Asked Questions on Form ADV and IARD
Renewal consequences are more mechanical. Failure to pay the preliminary renewal statement results in termination of the firm’s registrations and its representatives’ registrations, effective December 31. Reinstatement is not centralized. The firm must contact each jurisdiction individually, and many states impose fines for the lapse.12Investment Adviser Registration Depository (IARD). 2026 Investment Adviser Renewal Program
Public Disclosure Through IAPD
Everything filed through the IARD feeds the Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov. Anyone can search for a registered advisory firm and view its Form ADV, or look up an individual investment adviser representative to review employment history and disciplinary disclosures. The IAPD cross-references FINRA’s BrokerCheck system, so searches will flag whether an entity is also a brokerage firm.13U.S. Securities and Exchange Commission. IAPD – Investment Adviser Public Disclosure
That public visibility is the practical reason accuracy on Form ADV matters. Prospective clients, journalists, and regulators all use IAPD, and errors or omissions in what you file are visible to anyone who searches your firm’s name.