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Fall Regulatory Reminders, Rules and Updates: ID.Me, Filings and IARD Renewal, IA Continuing Education

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].

About the author

Jacko Law Group provides tailored legal services and effective strategies for success, delivering exemplary solutions to complex legal and regulatory challenges to ensure that both business efforts and compliance obligations are satisfied.

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Dharmi is an excellent securities lawyer who understands the law as it pertains to these cases. She is extremely proactive and represents her clients well. I highly recommend Jacko and Dharmi.
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I’ve had the privilege of working closely with this firm in my role as Chief Compliance Officer and I can confidently say they are an exceptional compliance partner. Their depth of experience is immediately evidentand they bring a level of practical knowledge. What I truly enjoy is their ability to translate complex regulatory requirements into plain English, often using real, everyday examples that make implementation far more manageable. They are also incredibly responsive and reliable. In a field where timing matters, their prompt communication and thoughtful guidance have been invaluable. If you’re looking for a compliance attorney who combines expertise, clarity, and professionalism, I highly recommend them.
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Michelle and the team at Jacko Law Group have helped guide through a variety of critical circumstances as we ventured through the uncharted and unfamiliar territory of becoming and successfully operating as an RIA. I have particularly appreciated Michelle's personal involvement and genuine caring about us and our organization. She has been responsive and her counsel has been consistently on-point and helpful. She artfully guided us through our initial filing process and first SEC exam process - which went very well. Very grateful to Michelle and her team.
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Michelle and her team were excellent to work with, front to back. They helped me to understand the challenges ahead and were always proactive in their consultation through every step of my transition. JLG truly know the wealth management industry very well and did a great job of understanding the challenges unique to my business. Without them, I can confidently say I would not have felt as comfortable through the transition as I did. Fortunately, that's not something that stops there - Michelle and her team have kept in touch to ensure that I'm on top of certain administrative issues, trends, and simply showing me that they care about my business and success. I look forward to continuing to work with them for many years to come.
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Dharmi and Amandeep were a delight to work with. They assisted me with a claim and stuck with me the entire way through. Dharmi's advice was invaluable, and I was most impressed by her clear and professional communication. From beginning-to-end, both Dharmi and Amandeep kept me well informed. Their entire team are proud of their work and rightfully so. Thank you!
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My mentor once told me that a good attorney is worth their weight in gold — and that couldn't be more true of Michelle and Amanda. Their expertise, professionalism, and responsiveness were top notch every step of the way. It's rare to find legal partners who are not only sharp and thorough, but also genuinely invested in your success. I’m grateful for their guidance and highly recommend them to anyone seeking trusted legal counsel.
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It is my great Privilege to share my Review of what Atty Dharmi Mehta of Jacko Law Group did for me and by extension for my family. From the first time complimentary conversation we had having spoken to several other Lawyers ,l knew she was the right person for the Job .Because of her background as a former RR ,she was professional,kind, Empathetic,listened and was focused on fighting for me. From a potential of been terminated with cause ,l was able to walk away with a clean U5 with a validation that l did nothing wrong except what was in the best Interest of my clients. I hope nobody ever has to go through what l have Experienced, but if you do ,you want Dharmi Mehta beside you .Rest assured your service Deserve 10 stars but this forum only allows 5. Me and my family are forever grateful and will make sure that any RR who needs an advocate will know about you . Everistus Etafo
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I have worked with Jacko Law Group for 2 different business situations that necessitated an attorney. In both cases, the team was very thorough & competent. Their attention to our situation and the extra effort they put into our case(s) was very much appreciated. I would highly recommend Jacko Law Group!