Since February 1, 2021, New York has required investment adviser representatives (IARs) — of both New York state-registered and SEC-registered (“federally covered”) advisory firms — to register with the state through the CRD system and meet its examination standards. New York was the last state to adopt this requirement, and it is now fully in effect.
The Investor Protection Bureau (IPB) of the New York State Attorney General’s office adopted these regulations — codified at 13 NYCRR Part 11 — which took effect February 1, 2021. Under them, IARs of both federal and state investment advisory firms must register with the state and meet certain qualification standards. New York provided a one-time implementation period that ran through December 2, 2021; that transition window has since closed, so any IAR acting in a capacity that requires registration must now be registered and approved before providing investment advice in New York.
The requirements apply to principals, supervisors, and representatives of firms, along with solicitors and certain IARs of federally registered firms. If you have IARs who do business in New York, the New York IPB recommends starting the registration process early.
Who Must Register as an IAR in New York?
Whether an individual must register comes down to the firm’s registration status and how the individual works with clients. The rules apply differently depending on whether the firm is SEC-registered or state-registered.
Historically, New York had been the only state that did not require IARs of federally registered investment advisers to register through the CRD/IARD system — though it did already impose an examination requirement.
For a federally covered (SEC-registered) adviser, the term “investment adviser representative” is defined under Rule 203A-3 of the Investment Advisers Act of 1940 to mean, generally, any supervised person of an SEC-registered adviser (including any officer, director, or partner) who:
- has more than 5 clients who are natural persons (excluding “qualified clients”); and
- has a client base more than 10% of which is made up of natural persons.
“Qualified clients” are, generally, clients who meet the SEC’s asset-under-management or net-worth thresholds — figures the SEC sets and periodically adjusts for inflation. A supervised person who has a place of business in New York and meets this definition must register as an IAR. A supervised person is not considered an IAR if they do not regularly solicit, meet, or communicate with clients, or if they only provide impersonal investment advice.
For New York state-registered advisers, the requirement is broader: all IARs, principals, and supervisors must register. At the firm level, a federally covered adviser generally must notice-file its Form ADV in New York once it has six or more clients in the state.
New York’s Exam Requirements and Waivers
Unless they qualify for a waiver, IARs must pass the Series 65 (Uniform Investment Adviser Law Examination), or the Series 7 and Series 66 in combination, within two years prior to filing their registration.
An investment adviser representative who has been continuously registered as an IAR in any jurisdiction for at least two years — with no regulatory or civil action, proceeding, or arbitration in the preceding 10 years — is exempt from the exam requirement. New York also recognizes waivers for individuals who hold certain professional designations:
- Certified Financial Planner (CFP)
- Chartered Financial Consultant (ChFC)
- Personal Financial Specialist (PFS)
- Chartered Financial Analyst (CFA)
- Chartered Investment Counselor (CIC); or
- another professional designation the administrator recognizes by rule or order.
Keep in mind that a disciplinary history can affect an individual’s eligibility for a waiver.
How to Register an IAR in New York
Registration runs through the CRD/IARD system. In practice, the process looks like this:
- Confirm the firm itself is registered or notice-filed in New York.
- File a Form U4 for each IAR through CRD and pay the $200 filing fee.
- Check whether each IAR qualifies for an exam waiver; if not, the IAR must complete the required examinations before the registration can be approved.
- Wait for New York to approve the registration before the IAR provides investment advice in the state.
- Update your internal policies and procedures to reflect these requirements.
New York registrations run on a calendar-year basis and must be renewed annually through CRD/IARD with the required fee, so keeping each IAR’s Form U4 current is an ongoing obligation, not a one-time task.
Does New York Require IAR Continuing Education?
Not currently. A growing number of states have adopted NASAA’s investment adviser representative continuing education (IAR CE) model rule, which requires 12 CE credits per year — but as of 2026, New York is not among them. That said, an IAR who is also registered in a state that has adopted the rule will still carry that CE obligation, so firms with multi-state IARs should track each individual’s requirements rather than assume New York’s approach applies everywhere.
Frequently Asked Questions
Do IARs Have to Register in New York?
Yes. Since February 1, 2021, IARs of both New York state-registered and SEC-registered advisers must register in New York through the CRD system if they have a place of business in the state and meet the applicable IAR definition.
Who Is Exempt From the New York IAR Exam Requirement?
An IAR who has been continuously registered as an IAR in any jurisdiction for at least two years with a clean 10-year disciplinary record may qualify for a waiver, as may individuals who hold certain designations — CFP, ChFC, PFS, CFA, or CIC.
How Much Does New York IAR Registration Cost?
The Form U4 filing fee for an IAR is $200, paid through the CRD/IARD system, plus any exam costs for IARs who do not qualify for a waiver. Registrations then renew annually.
Get Help With New York IAR Registration
Core Compliance can assist with New York IAR registration and all of your regulatory filing requirements. Contact us at (619) 278-0020 or reach out online to schedule a consultation.
