Don’t Exaggerate AUM

posted in: Registration & Licensing | 0

Assets under management is a defined term on Form ADV. Don’t exaggerate to stay registered with the SEC. The SEC has enforcement actions underway against multiple SEC-registered advisory firms that puffed up their assets.

Common Registration Deficiencies

posted in: Registration & Licensing | 0

Applicants for investment adviser registration should not only be concerned about the accuracy of their firm’s primary registration documents (i.e., Form ADV Part 1 and Part 2A), but also that these documents, along with the firm’s advisory agreements, are consistent … Continued

IARD User Fees

posted in: Registration & Licensing | 0

IARD user fees are always a source of confusion. That is because advisers swear up and down that they paid their renewal fees and this additional fee must be a mistake. But IARD user fees are separate and apart from … Continued

Changes to Massachusetts IAR Registration?

posted in: Registration & Licensing | 0

On March 15, 2013, the Massachusetts Securities Division (the “Division”) filed regulations proposing amendments with respect to investment adviser representative (“IAR”) applications.  If made effective, the IAR application process would change and may affect your firm’s registration process for all … Continued

SAA Entitlement Certification

posted in: Registration & Licensing | 0

Even though you may get a message from FINRA to the contrary, investment advisory firms with only one registered investment adviser do not have to go through the annual SAA certification process. In fact, you can’t.

Super Account Administrator

posted in: Registration & Licensing | 0

Important News from FINRA: As you may be aware, one of your responsibilities as your firm’s Super Account Administrator (SAA) is to complete the annual FINRA Entitlement User Accounts Certification Process. This certification process–which for 2013 begins Jan. 14 and … Continued

Common Deficiencies

posted in: Registration & Licensing | 0

In order to provide state-registered investment advisers with a better understanding of what they need to do to “stay out of trouble” we analyzed all the state-level compliance material (e.g., examination request lists, deficiency letters, policy notices, speeches) we have … Continued

California Requirements

posted in: Registration & Licensing | 0

For those SEC-registered advisers transitioning to registration in the State of California, you need to include the following two disclosures in your ADV Part 2A: “XYZ Advisors has disclosed all material conflicts of interest under section 260.238(k) of the California … Continued

1 2 3