On October 7, 2011 the California Department of Corporations issued a notice to mid-sized investment adviser firms transitioning to California state registration. According the release, current investment adviser firms that are regulated under the U.S. Securities and Exchange Commission (“SEC”) that are considered mid-sized investment adviser firms (with assets under management between $25 and $100 million), are highly encouraged to file as soon as possible the appropriate state application and paperwork to transition to regulation under the State of California. The California Department of Corporations is anticipating a “high volume of transition applications, which will be reviewed in the order received.” The release also advised investment adviser firms to respond promptly to any requests for additional information and/or application revisions. The release highlighted some important dates for investment advisers to note:
- “All SEC Investment Advisers must file an annual updating amendment before March 30, 2012, whether you have a pending State Application or have not yet submitted a [California] application. Your firm can submit the CA Application at the same time the annual updating amendment is filed.”
- “If your firm’s application is submitted and approved prior to January 1, 2012, you may elect to either have your firm’s CA registration approved for 2011 OR request that the [California Department of Corporations] hold the completed application and approve it effective January 1, 2012.” Those firms that receive approval prior to January 1, 2012 and wish to be approved for CA registration for 2011 would be required to pay two renewal fees, once in 2011 and again in 2012.”
For additional information regarding transitioning your investment adviser firm from SEC to California state registration, please click here to register for RIA Compliance Consultants free webinar, hosted October 20, 2011 at 12:00 Central.
Posted by Bryan Hill
Labels: Annual Amendment, SEC, Switch from SEC to State