As of July 1, 2017 the State of Wyoming will require investment advisers to register with Wyoming securities regulators if the investment adviser has less than $100 million of assets under management (AUM) unless it meets another criteria for registering with the U.S. Securities and Exchange Commission (“SEC”). Wyoming had been the only state that did not regulate investment advisers.
An investment adviser with a principal office in Wyoming, which has less than $100 million of assets under management and does not otherwise qualify for SEC registration, will need to file a new Form ADV with Wyoming and a partial ADV-W withdrawing from SEC registration after the Wyoming investment adviser registration has been approved.
The following is a brief summary of the State of Wyoming’s new investment adviser registration requirements
- Investment adviser representatives (IARs) exam requirements
- Series 65 or Series 66 AND Series 7
- Examination exemptions for CFP, ChFC, CFA, PFS, and CIC designations
- Grandfathering IARs – There will be a time frame for which IAR’s will need to be registered in order to qualify. Proof of registration in another state, as long as that other state required the applicant to pass the Series 65 examination or the Series 66 and Series 7 examinations together or specifically waived that requirement for the IAR when the IA was registered by that state, shall be accepted in lieu of the examination requirements for all IAR’s registered in Wyoming within a specified time frame (TBD).
- Investment adviser registration fee $250
- Investment adviser renewal fee $250
- IAR registration fee $45
- IAR renewal fee $45
- SEC registered firms notice filing fee $250
- A written supervisory policies and procedures manual will be required
- If your investment adviser firm does not have an office location in Wyoming and your investment adviser firm has 6 or more clients in Wyoming your firm will have to register in Wyoming Pursuant to Wyoming Securities Act 17-4-403 (b)(ii)
If your investment adviser is located in Wyoming or has clients in Wyoming, we encourage you to contact your Compliance Consultant at RIA Compliance Consultants. Your compliance consultant can walk you through the new legislation and help you determine if you need to register in Wyoming.
Wyoming Securities Act that will take effect July 1, 2017 http://soswy.state.wy.us/Investing/Docs/Wyoming_Securities_Act_Effective_07-01-2017.pdf
Wyoming Investment Advisers FAQ page http://soswy.state.wy.us/Investing/Docs/investment_faq_final.pdf
Posted by Grant Parr
Labels: Wyoming Investment Advisor