Deadline Looming For ADV Renewals

If you are a registered investment adviser, today is the last day to remit payment to your investment adviser's IARD renewal account. All monies must be delivered to FINRA by December 13, 2010 to meet FINRA's deadline. If you have not done so already, please follow the instructions below and submit your fees to avoid termination. The U.S. Securities and Exchange Commission, and each state's securities division, require all registered investment advisers to annually renew their registration. Please review your Renewal Statement to determine what fees need to be paid in connection with your renewal. The fee is paid directly to IARD.

Payment must be received by December 13, 2010. Failure to remit payment of the Renewal Statement by December 13, 2010 may result in your inability to conduct business in jurisdictions where you are registered as of January 1, 2011. Additionally, failure to remit payment may result in the termination of your investment adviser representative registrations, effective December 31, 2010. The following are the available payment options:

1. Electronic payment via Web CRD/IARD E-Pay. This option allows you to authorize electronic payment directly from your designated bank account to your renewal account. Please go to website for further details.

*Web E-Pay Update: If you have not used Web E-Pay since August 20, 2006, the first time you log onto Web E-Pay you will be required to enter your current user ID and a new password. The new password is your user ID + your firm's CRD number (all as one string, no spaces). You will be required to change your password after this initial logon in order to submit an electronic payment.

2. Payment by wire transfer. You may wire funds into your renewal account. Wire transfer deposits received before 2 p.m., EST, should be posted in your daily account the next business day. Wire transfer deposits received after 2 p.m., EST, should be posted in your daily account within two business days. You may wire funds into your financial account as follows:

- Instruct your bank to contact: "Mellon Financial, Philadelphia, PA.".

- Provide your bank with the following information to initiate a wire transfer:

• ABA Number: 031 000 037

• Beneficiary: FINRA

• FINRA Account Number: 8-234-353

• Reference Number: Your Firm's CRD Number

3. Payment by check. While FINRA makes every attempt to process checks within one business day, processing may take up to two business days or more (after receipt) during the renewal season. Please remember to write your firm's CRD number and the word "Renewal" on the face of the check. Additionally, print the first page of the Renewal Statement and send it with your check.

4. Payment by transfer of funds from your firm's daily account to your firm's renewal account. In an effort to assist you with your renewal payment, if your firm currently has enough funds in its daily account to cover the cost requirements for the renewal statements, on December 13, 2010, FINRA will automatically transfer the funds into your firm's renewal account.

Once the Renewal Statement has been filed and the payment is made, you can continue with the renewal process, which includes revisions to the Form ADV to reflect current and accurate information, including relevant changes to your firm's business. The annual amendment to the firm's Form ADV will be due, at the latest, 90 days after year-end. If the payment is not made by December 13, 2010, you will not be able to continue with the renewal process, which may result in your inability to conduct business in jurisdictions where you are currently registered or termination of your investment adviser representative registrations, effective December 31, 2010.

If you have any questions regarding the renewal process or payment, please feel free to contact Daniel G. Viola at 212-573-8038.

Cheryl Spratt