It’s likely that your investment advisor firm is currently working on its Form ADV annual amendment since it must be filed within ninety (90) days after an advisor’s fiscal year end. You should pay particular attention to updating the firm’s assets under management since regulators have stated an advisor’s assets under management must be current as of the firm’s most recently completed fiscal year.
Once you’ve calculated your investment advisor’s assets under management, you must determine whether your firm will need to change from a state to SEC registration or conversely from an SEC to state registration. When a firm’s assets exceed $30 million, the firm must be registered directly with the SEC. A firm with assets under $25 million must register with the applicable individual states. If a firm’s assets under management are between $25 million to $30 million, the firm can choose between SEC or state registration.
If your firm’s assets under management now exceed $30 million (or are significantly above $25 million) for the first time, do you know the steps that must be taken to register with the SEC? Has your firm developed a code of ethics and set of written supervisory policies and procedures? Are you ready for an SEC examination? If you need help calculating assets under management, completing the Form ADV annual amendment or filing your registration with the SEC, please give us a call.