With Q4 underway, it is time to prepare for 2027. Here are the regulatory reminders you need to stay compliant in the new year.
MANDATORY ID.ME IDENTITY VERIFICATION
As firms prepare to meet their filing and renewal obligations, it is important to consider FINRA’s new Mandatory ID.me identity verification which took effect in May 2026. The new ID verification is required to access FINRA’s gateway systems. Delays in ID verification can delay time-sensitive regulatory filings and renewals, including IARD renewal payments.
Please note that FINRA now requires ID.me identity verification for in-scope users logging into its systems, including IARD. If you haven’t completed verification, do so before the IARD renewal window opens so you aren’t locked out when your Preliminary Renewal Statement is available.
IARD RENEWALS
Investment advisers (“IAs”) and their IARs are required to pay their IARD renewal fees each year to remain active. Failure to pay on time can result in penalties ranging from late fees to suspension or termination of the firm’s and representatives’ registrations.
IAs can access their IARD Preliminary Statement through their IARD account starting November 9, 2026. The statement details the firm’s annual IARD charges and state renewal fees.
Please note that payments must be made by December 7, 2026, to maintain compliance.
The last day to submit form filings is December 27, 2026, at 6 p.m. ET (3 p.m. PT) as the IARD and CRD will be inaccessible after that time through January 2, 2027.
INVESTMENT ADVISER REPRESENTATIVE (“IAR”) CONTINUING EDUCATION (“CE”) CREDITS
IARs operating in states participating in the North American Securities Administrators Association™ (“NASAA”) are required to submit 12 CE credits by December 31, 2026. The CE credits must meet the requirements, which includes six (6) CE credits in Ethics and Professional Responsibility, and six (6) CE credits in Products and Practice.
Only IARs in states that are participating in the NASAA CE program are required to submit these CE credits; however, the program continues to expand with more states joining every year.
In 2026, Illinois made IAR CE credits a requirement. Indiana will participate in the NASAA CE program starting in 2027.
To learn more, view the IAR CE Map here to see the updated list of participating states.
IMPORTANT
IARD SYSTEM SHUTDOWN
IARs should aim to satisfy their CE requirements and submit them to the Central Registration Depository (“CRD”) and the Investment Adviser Registration Depository (“IARD”) systems by mid-December as the systems typically shut down in late December to process registration renewals and perform other updates.
For assistance meeting your filing requirements, and other regulatory needs, please contact us at 619.298.2880 or email [email protected].