IAR Registration Requirements

Overview

• Investment adviser representatives (IARs) follow essentially the same registration process as agents.
• The registration exemptions that apply to investment advisers also apply to IARs.

🔑 Numbers & deadlines

Disclosures and fees

The disclosures and fees for an agent’s registration are the same for IARs. Summary of what is requested on Form U4 and the general requirements:

Effective registration

• Once the required disclosures are made and the filing fee is paid, the state administrator grants effective registration (typically on the 30th day after filing).
• ⚠️ As with broker-dealers, agents, and state-registered investment advisers, IARs can’t imply that the administrator has approved them when discussing their registration.

⚠️ Two ways IAR registration is different

Example (from the text): an IAR works for a covered adviser with an office in Florida, but calls hundreds of potential retail clients in Alabama. That IAR registers in Florida only (no Alabama registration required).

*Agents and IARs of state-registered advisers must register in any state they do business in unless an exemption exists (e.g., the institution exemption).

Financial requirements for IARs

• No minimum financial requirements.
• Insolvency may affect registration status.

Sidenote: Dual registration

Many securities industry professionals are dual-registered as IARs and agents. Holding both registrations allows an individual to:

• Firms that employ dual-registered individuals must be dual-registered as broker-dealers and investment advisers.

Termination

The termination notification process for IARs is similar to the process for agents, but there are a few key differences.

• Form U5 is still used to notify the state administrator. The main difference is who files it.

• When a termination occurs, the state administrator must be notified by the appropriate party “promptly.”
• The administrator will then cancel the IAR’s registration within 30 days of notification.
• ⚠️ Even after the registration is canceled, the administrator may still pursue punitive actions (for example, a suspension or revocation*) for up to one year after the withdrawal.

Example (from the text): an IAR committed an unethical act during employment, but the administrator doesn’t discover it until after the IAR is terminated. The administrator can still impose discipline up to one year after the registration was withdrawn, even though the individual is no longer registered. That disciplinary history can make it harder to re-enter the industry later.

*A suspension is a temporary loss of registration, while a revocation is a permanent loss of registration. These punitive actions are covered in detail in a future chapter.

Exemptions

IARs receive three of the same exemptions available to investment advisers:

Continuing education

• Registered individuals (agents and IARs) must maintain current, industry-related knowledge. Passing a licensing exam is only part of the requirement — registered individuals must also complete continuing education (CE).
• The North American Securities Administrators Association (NASAA) imposes annual CE requirements for IARs.

*NASAA defines a credit as at least 50 minutes (roughly 1 hour) of educational instruction.

**IAR Products and Practice Content is not required for IARs dual-registered as agents because this information is covered in agent-based CE (discussed below).

• IAR CE is delivered by training organizations that NASAA calls “authorized providers.”
• The authorized provider reports CE completion, but the IAR is responsible for confirming that the report was received.
• CE must be completed annually. ⚠️ If it isn’t completed, the IAR becomes ineligible to renew registration.

Agent continuing education

• Agents also have annual CE requirements, but those are imposed by FINRA (not NASAA).
• 📌 Because you’re preparing for a NASAA exam, you’re unlikely to see test questions on agent CE requirements.

Key points

Form U4

• Registration form for IARs

IAR registration disclosures

• List of all current registrations
• Employment & residential history
  • 10 years of employment history
  • 5 years of residential history
• Criminal events
  • Any charges, guilty pleas, no contest pleas, or convictions must be disclosed
  • Guilty pleas, no contest pleas, and convictions of felonies or securities-related misdemeanors in the past 10 years may prevent registration
• Regulatory events
• Court actions
• Financial disclosures
  • Bankruptcy filings
  • Compromises with creditors
• Payment of filing fee

Effective registration

• Must submit the proper paperwork, disclosures, and fees
• IARs of federal-covered advisers only register in states where an office exists
• Typically granted on the 30th day after filing

Financial requirements for IARs

• No minimum financial requirements
• Insolvency may affect registration status

Form U5

• Terminates IAR’s registration status
• Filed when an IAR quits or is terminated
• Responsibility of:
  • Investment adviser if the firm is state-registered
  • IAR if the firm is federal-covered
• Administrator may institute disciplinary actions up to a year after withdrawal

IAR exemptions

• Snowbird/vacation rule
  • No place of business in the state
  • Only engaging investors temporarily in that state
• Institution rule
  • No place of business in the state
  • Only engaging institutional investors in that state
• De minimis rule
  • No place of business in the state
  • Engaging no more than 5 retail clients in a 12-month period in that state

IAR continuing education (CE)

• Must be completed annually
• Ineligible for registration renewal if not completed
• Facilitated by authorized providers
• 1 credit = roughly 1 hour of educational material

IAR CE courses

• IAR Regulatory and Ethics Content (6 credits)
  • At least 3 ethics credits
• IAR Products and Practice Content (6 credits)
  • Not required for IARs dual-registered as agents

Agent continuing education

• Imposed and facilitated by FINRA

Sources

Primary/official references for the material in this chapter. Every link was fetched and returned HTTP 200 on 2026-08-15.