Does your investment advisor firm have an office location in a state that requires branch office registration? If so, have all of your office locations been properly reported to the appropriate state regulatory office? Depending on whether your firm is SEC or State registered, your firm may need to register its investment advisor office locations in states that require such filings. These requirements are in addition to reporting office locations on the ADV Part I.
Beginning on Monday, October 31, Web CRD will be updated to facilitate the filing of advisor firm branch office filings. In addition, some states will also require branch office renewal fees to be paid through Web CRD. To read the NASAA press release concerning this new Web CRD functionality and view a table of states that will require branch office filings through Web CRD, click here.
Regardless of whether your firm is SEC or state registered, if the firm has a physical office location in a state, the firm will need to be notice filed (if SEC registered) or registered (if at the state level) in that state. A notice filing or registration is also needed for firms that advertise in a state. For states in which an advisor firm simply has clients, the firm must be aware of the state’s client de minimus exemption. Of course there are exceptions to these general guidelines and states have different requirements for the licensing of advisor representatives. If you have any questions on where your firm, representatives, or branch offices need to register, give us a call.