IAR Registration & Post-Registration Requirements
Once qualified, IARs must complete registration and maintain ongoing compliance with various requirements, including continuing education.
Form U4 Registration
The Uniform Application for Securities Industry Registration or Transfer (Form U4) is the registration document for IARs.
Required Information on Form U4
| Category | Details |
|---|---|
| Personal Information | Name, SSN, date of birth, residential addresses (5 years) |
| Employment History | Complete history for past 10 years |
| Education | Schools attended, degrees obtained |
| Disclosure Questions | Criminal, regulatory, civil, financial, termination history |
| Fingerprints | Required in most states |
| Exam Information | Exams passed or designations held |
Disclosure Questions
Form U4 requires disclosure of:
| Category | Must Disclose |
|---|---|
| Criminal | Felony charges/convictions, certain misdemeanors |
| Regulatory | Disciplinary actions, investigations, sanctions |
| Civil | Investment-related lawsuits, arbitrations |
| Customer Complaints | Written complaints alleging sales practice violations |
| Terminations | For cause, permitted to resign, allegations |
| Financial | Bankruptcies, liens, judgments, bonding failures |
Filing Through CRD/IARD
| System | Purpose |
|---|---|
| CRD | Central Registration Depository—manages registrations |
| IARD | Investment Adviser Registration Depository—IA firm filings |
| Electronic Filing | All Form U4 filings are electronic |
| State Fees | Vary by state, paid through IARD |
Amendment Requirements
Timing for Form U4 Amendments
| Type of Change | Amendment Deadline |
|---|---|
| Disclosure Events | Within 30 days |
| Criminal Charges | Within 10 days |
| Name/Address Changes | Within 30 days |
| Material Changes | Promptly (generally 30 days) |
On the Exam: Criminal charges (not just convictions) must be disclosed within 10 days—a shorter timeframe than most other amendments.
Continuing Education Requirements
NASAA IAR CE Model Rule
Most states have adopted continuing education requirements:
| Requirement | Details |
|---|---|
| Total Credits | 12 credits annually |
| Products & Practice | 6 credits required |
| Ethics & Professional Responsibility | 6 credits required |
| Credit Definition | 1 credit = at least 50 minutes of instruction |
| Annual Deadline | December 31 |
CE Content Areas
Products & Practice (6 credits):
- Investment products and strategies
- Portfolio management techniques
- Regulatory compliance
- Industry standards and best practices
Ethics & Professional Responsibility (6 credits):
- Fiduciary duties
- Conflicts of interest
- Professional standards
- At least 50% must cover ethical responsibility
First-Year Exception
| Situation | CE Requirement |
|---|---|
| New Registration | No CE required until January 1 of following year |
| Example | IAR registers February 2025 → CE begins January 1, 2026 |
Non-Compliance Consequences
| Stage | Consequence |
|---|---|
| CE Not Completed by Dec 31 | Status set to "CE Inactive" |
| CE Inactive Status | Appears on IAPD and BrokerCheck |
| Continued Non-Compliance | Unable to renew registration |
| Extended Non-Compliance | Registration termination |
Termination and Form U5
Form U5 Requirements
| Requirement | Details |
|---|---|
| Filing Deadline | Within 30 days of termination |
| Filed By | The investment adviser firm |
| Contents | Reason for termination, disclosure updates |
| Public Record | Follows individual's registration record |
Reasons for Termination
| Code | Description |
|---|---|
| Voluntary | IAR resigns on own accord |
| Permitted to Resign | Resigned while under investigation |
| Discharged | Terminated by firm |
| Other | Business reasons, restructuring |
Exam Validity After Termination
| Time Since Termination | Requirement |
|---|---|
| Within 2 Years | Can re-register without re-taking exam |
| After 2 Years | Must re-take qualifying exam |
| State Variations | Some states have different rules |
Supervision Requirements
Adviser Responsibilities
| Obligation | Details |
|---|---|
| Written Procedures | Establish supervisory policies |
| Designated Supervisor | Assign supervision responsibility |
| Transaction Review | Review IAR trading activity |
| Correspondence Review | Monitor client communications |
| Training | Ongoing compliance education |
| Annual Compliance Review | Evaluate effectiveness of procedures |
IAR Responsibilities
| Obligation | Details |
|---|---|
| Follow Policies | Adhere to firm procedures |
| Accurate Records | Maintain proper documentation |
| Disclosure | Report required information |
| Act Within Authority | Stay within granted powers |
| Report Issues | Escalate problems to supervisor |
Key Takeaways
- Form U4 requires 10-year employment history and 5-year residential history
- Criminal charges must be reported within 10 days; most other changes within 30 days
- IAR CE requires 12 credits annually: 6 Products & Practice + 6 Ethics
- Form U5 must be filed within 30 days of termination
- Exam validity: 2 years from termination date
Test Your Knowledge
The annual continuing education requirement for IARs under the NASAA model rule is:
A
B
C
D
Test Your Knowledge
When an IAR is terminated, the investment adviser must file Form U5:
A
B
C
D
Test Your Knowledge
An IAR who has been terminated for 18 months wishes to re-register. They must:
A
B
C
D
Up Next
14.3 IARs of Federal Covered Advisers
Continue learning
Get free exam tips·