Each year, investment advisers and their registered personnel are required to renew their registrations for the following year, to ensure that continuous registrations are maintained. This also marks a key time for advisers to review their current registrations and notice-filings, as well as their active rosters of registered personnel, to confirm that all registrations and notice-filings are maintained in all appropriate jurisdictions. Please reach out to [email protected] for help this year.

Recommended Actions

Form U4 Review, Updates, and Renewal Fees

During the annual renewal process, we suggest that advisers review their roster of registered personnel, their registration statuses, and the contents of their representatives’ Form U4. As part of that process, the firm should:

• Ensure that all personnel are registered in all appropriate jurisdictions;

• Terminate the registration of personnel who are no longer associated with the firm or registrations of personnel whose job activities no longer necessitate registration;

• Prepare and file Form U4s for personnel who are not yet registered but whose job activities necessitate registration;

• Update or re-confirm the details contained in each registered person’s Form U4;Ensure that representatives remain in good standing with any advertised professional designations; and

• Ensure that adequate funding is maintained in the firm’s FINRA account to cover the respective renewal fees.

Changes to a representative’s Form U4 (e.g., changes to job title, changes to outside business activities, etc.) may result in changes to the representative’s Form ADV Part 2B, if applicable.

Notice Filing (SEC-Registered Firms) and Firm Registration (State-Registered Firms)

Firms should review their current notice-filing status (on Form ADV Part 1, Item 2) or state registration status (on Form ADV Part 1B Item 1) to:

• Ensure the Firm is notice filed or registered in all appropriate jurisdictions based on the number of client households in each;

• Ensure the Firm is notice filed or registered in all appropriate jurisdictions based on where it maintains places of business;

• Withdraw any notice filings or state registration if they are no longer required; and

• Ensure that adequate funding is maintained in the firm’s FINRA account to cover the respective notice filing or registration fees.

Industry Resources

Registrations and registration renewals are completed through the FINRA Gateway system. Below is guidance that FINRA has published about the renewal process, including answers to some of the most frequently asked registration renewal questions:

• FINRA Annual Renewal Guidance
• FINRA Renewal FAQs

Key Dates

Here are some dates to keep in mind for the annual renewal process:

• October 2025: Review and update roster, as necessary
• November 10, 2025: Preliminary renewal statements issued
• December 8, 2025: Deadline for receipt of preliminary renewal statement payments
• January 2, 2026: Final renewal statements issued.
• January 23, 2026: Deadline for receipt of final renewal statement payments. Excess funds paid towards preliminary renewal statements are swept to firm’s FINRA Flex-Funding Account.

Ask For Help!

Determining registration and notice-filing requirements for firms and firm personnel can be complicated. Use of the FINRA Gateway system for registrations and renewals presents its own unique set of questions. Please do not hesitate to reach out to [email protected] if you have any uncertainty about whether and to what extent your firm or personnel need to be registered, or if you need any other help navigating the annual renewal process. Thank you!