While it may be hard to believe, 2020 is already coming to a close, which means broker-dealers and investment advisors’ 2021 Renewal Programs are officially underway. Unlike many other filings in 2020, there will be no regulatory relief for late filings or payments due to the ongoing COVID-19 pandemic. As a result, the following dates should make their way on your 2020 calendar, to ensure no late fees this year.
Renewal fees are provided through two statements:
- The Preliminary Statement reflects registration information as of mid-November.
- The Final Statement reflects registration information as of January 1.
Preliminary Statement Period
Preliminary Statements are generated in mid-November. They reflect currently approved registrations that have not been terminated, including post-dated filings submitted before the statement is generated. Below are some important deadlines to keep in mind when it comes to this statement period.
ASAP: Review and Prepare for the 2021 Renewal Program.
- Download important renewal dates to your calendar.
- Take note of changes on the CRD/IARD Availability page.
- Confirm that the information for the Renewal Contact in FINRA Gateway is current.
- Enable email alerts about the Renewal Program in E-Bill.
- Review firm, branch and individual registrations to ensure registrations are renewed.
OCTOBER 19: Begin Preparing Post-Dated Forms U5 and BR Closing/Withdrawal Filings.
Starting October 19, 2020, firms can submit Forms U5 and BR Termination filings with a termination date of December 31, 2020. Submitting these filings allows firms to request termination of registrations in advance. Registrations terminated through these post-dated filings before Preliminary Statements are generated, will not be included for renewals.
NOVEMBER 1: Begin Preparing Post-Dated Forms BDW and ADV-W.
Starting November 1, 2020, firms can initiate Forms BDW and ADV-W filings with a termination date of December 31, 2020. Submitting these filings allows firms to request termination of registrations in advance. Registrations terminated through these post-dated filings before Preliminary Statements are generated, will not be included for renewals.
NOVEMBER 16: Retrieve (and Schedule Payment for) the Preliminary Statement in E-Bill.
Preliminary Statements are available in E-Bill beginning November 16, 2020. Many firms find it convenient to submit or schedule their payment while logged in to E-Bill to retrieve the statement. Preliminary Statement reports are also available in CRD/IARD. Be sure to save or print these reports before Final Statements are generated as they cannot be recreated once the Final Statement is created.
DECEMBER 14: Ensure Full Payment is Available in Renewal or Flex-Funding Account by This Date.
FINRA-registered firms should ensure payment is received and posted to your account by this day. Money can be deposited directly into your firm’s Renewal Account, or firms may rely on FINRA to transfer the money from your firm’s Flex-Funding Account beginning December 14, 2020. In order to take advantage of this transfer, the complete amount due for renewals must be available in your firm’s Flex-Funding account. Firms must pay the entire amount assessed on the Preliminary Statement. Failure to remit full payment of their Preliminary Statement to FINRA by December 14, 2020, may cause FINRA-registered firms to be subject to a late fee.
DECEMBER 26: Submit Filings and Payments Before the 2020 Deadline at 6 pm ET.
The CRD/IARD system shuts down for the year at 6 pm on December 26, 2020. Firms should ensure that they perform the following activities before the shutdown occurs:
- Submit/terminate registration filings.
- Finalize any E-Bill renewal payments or transactions. Firms that missed the payment deadline must ensure that renewal funds are posted by this date. At 6:00 pm ET, any unpaid Preliminary Statement will result in jurisdictions automatically terminating registrations for failing to renew (which will result in the inability to conduct business in these jurisdictions effective January 1).
- Print and/or save renewal reports in CRD/IARD. On January 2, Preliminary Statement reports will be replaced with Final Statement reports
- Several CRD/IARD system outages occur during the Renewal Program. See the CRD/IARD Availability page for details.
Final Statement Period
Final Statements are made available in January. They display the registrations that were renewed for January 1 and any amount owed by the firm. If a firm overpaid the amount owed for the Final Statement, the overpayment was transferred to the firm’s Flex-Funding account.
JANUARY 2: Retrieve and Schedule Payment for the Final Statement in E-Bill.
Final Statements are available in E-Bill on January 2, 2021. Preliminary Statement reports are replaced with Final Statement reports in CRD/IARD. Many firms find it convenient to schedule any required payment while logged in to E-Bill to retrieve the statement. If additional payment is not required, the Final Statement will reflect “Paid in Full.” Any overpayment FINRA received from a firm is now available in the firm’s Flex-Funding account.
JANUARY 22: Ensure Discrepancies are Reported or Balance is Paid.
Firms must submit any amount owed on the Final Statement to FINRA by this day. Money can be deposited directly into the Renewal Account, or firms can rely on FINRA to transfer funds from the firm’s Flex-Funding Account beginning January 22, 2021. In order to take advantage of this transfer, the complete amount due for renewals must be available in your firm’s Flex-Funding account. See the Renewal Payment Options page for more information. January 22, 2021 is also the deadline for firms to report in writing to FINRA any discrepancies found on the Final Statement. FINRA must receive this by January 22, 2021.
See the following checklist for similar dates regarding the 2021 IARD Renewal Program for Investment Advisers.