IARD user fees are always a source of confusion. That is because advisers swear up and down that they paid their renewal fees and this additional fee must be a mistake. But IARD user fees are separate and apart from your renewal fees. Renewal fees take care of your firm’s various registrations (e.g., state, notice filing, investment adviser representatives). IARD user fees are assessed for the electronic filing of forms for your firm’s registration on the IARD system. This fee is charged at the time your firm submits its Annual Amendment, which is due within 90 days following the end of your firm’s fiscal year.
Only SEC-registered investment advisers and SEC Exempt Reporting Advisers are subject to the annual fees. It has traditionally been waived for state registrants.
The fees are as follows:
Assets Under Management Annual Fee
SEC Registrant Under $25 Million $40
SEC Registrant Under $25 – $100 Million $150
SEC Registrant Over $100 Million $225
SEC Exempt Reporting Adviser $150