As your state registered investment adviser firm completes its Form ADV Annual Amendment, it’s important not to forget that many state securities regulators also require a state registered investment adviser firm to submit annual financial statements and/or other documents (e.g., proof of continued coverage of a surety bond, investment advisory client agreement if material changes) directly to the state securities regulator (outside of the IARD/CRD system).
As your state registered investment adviser firm completes its Form ADV Annual Amendment, it’s important not to forget that many state securities regulators also require a state registered investment adviser firm to submit annual financial statements and/or other documents directly to the state securities regulator (outside of the IARD/CRD system).
Florida’s Office of Financial Regulation Securities Division Reports on Investment Adviser Registrations Due to Switch
October 25, 2012
In a recent article in the Florida Current, it was reported that 315 investment adviser firms have applied for state registration with Florida’s Office of Financial Regulation Division of Securities due to the new rule of the U.S. Securities and Exchange Commission (“SEC”) requiring mid-sized investment adviser firms to switch from SEC to state registration. Despite four administrative positions being cut in the Division of Securities and the resignation of the director of the Division of Securities, Florida’s Office of Financial Regultion reports that it has approved 149 of the 157 Florida based investment adviser firms that have applied for state investment adviser registration due to the switch; however, there was no reference in the article as to how many of the out-of-state investment adviser registration applications due to the switch that have been approved by the Florida Division of Securities.
August 24, 2012
Fifteen states require investment advisers to register their branch offices with the state securities regulator. Currently, the Alabama Securities Commission, the Arkansas Securities Department, the Connecticut Department of Banking, Securities and Business Investments Division, Florida’s Office of Financial Regulation , Hawaii’s Department of Commerce and Consumer Affairs, Idaho’s Department of Finance, the Illinois Securities Department, Maine’s Office of Securities, the New Hampshire Bureau of Securities, the New Mexico Securities Division, the Ohio Department of Commerce, the Texas State Securities Board, Vermont’s Department of Financial Regulation, the West Virginia Securities Commission, and Wisconsin’s Department of Financial Institutions require investment adviser branch offices to register with state securities regulators. Some of these 15 state securities regulators require an investment adviser branch office registration fee while other states only require registration of each investment adviser branch located in their state. For state securities regulators that do charge branch office registration fees, the charges range from $20 (by the Illinois Securities Department) to $300 (by the New Mexico Securities Division). For further information on the investment adviser registration requirements in each state, refer to the North American Securities Administrators Association (“NASAA”) website.