Under certain circumstances, an investment adviser firm registered with the U.S. Securities and Exchange (“SEC”) is not required to file/deliver the new Form ADV Part 3/CRS relationship summary.
On June 10, 2020 the State of Rhode Island’s Securities Division announced that investment adviser firms registered with the State of Rhode Island must file the Form ADV Part 3/Form CRS relationship summary before June 30, 2020. Click here to read Rhode Island’s Notice to Investment Advisers RE: Form CRS. This is significant because Rhode Island is now the second state securities regulator to require the filing of the Form ADV Part 3/Form CRS by a state-registered investment adviser firm. Previously, to the best of our knowledge, only the Oklahoma Department of Securities and SEC registered investment adviser firms with retail investors were required to file the Form ADV 3/Form CRS. (Regulatory Update: On June 19, 2020, the Oklahoma Department of Securities withdrew (effective immediately) its notice requiring investment adviser firms registered with Oklahoma to file the Form ADV Part 3/Form CRS.)
In June 2019, the U.S. Securities and Exchange Commission (“SEC”) adopted a new rule requiring SEC registered investment adviser firms to prepare and deliver an easily accessible and understandable Consumer Relationship Summary, also known as the Form CRS or Form ADV Part 3, to retail investor clients. An SEC registered investment adviser’s initial Form CRS/Form ADV Part 3 must be filed with the SEC by June 30, 2020 and delivered to existing clients no later than July 30, 2020. Click here to read our recent blog on the SEC’s decision to maintain the original June 30, 2020 filing deadline.
The U.S. Securities and Exchange Commission (“SEC”) recently provided guidance on the disclosure obligations of an investment adviser firm when receiving a Paycheck Protection Plan (“PPP”) loan guaranteed by the U.S. Small Business Administration in conjunction with the relief afforded from the CARES Act during the COVID-19 pandemic.
September 05, 2019
You only have one week to register for our 2019 Investment Adviser Compliance Conference. There is still time for you to choose to either join us and fellow investment adviser compliance professionals in Omaha, NE on Sept. 11 and 12 or watch our LiveStream broadcast of Day 2 of the conference (Sept. 12) from the comfort of your desk.
Join RIA Compliance Consultants on Wednesday, September 11 and Thursday, September 12 at the Scott Conference Center in Omaha, NE. Don’t miss this opportunity to learn from industry experts, engage with like-minded peers, and connect with the top leaders in the industry all in the name of the best interest of your clients. Need more convincing?
November 02, 2018
Now is the time for each registered investment adviser to begin preparations for IARD renewals for the investment adviser firm and its investment adviser representatives. Registered investment advisers must make sure that they always remain properly registered. If you are an SEC registered investment adviser, you must make sure that your investment adviser is notice filed in all required states. If you are a state registered investment adviser, you must make sure your investment adviser is properly registered in all required states. Generally, registration or notice filing is required at the firm level if an investment adviser has a place of business in the state or if it exceeds the state’s de minimus exemption. However, investment advisers must review each state’s notice filing or registration requirements prior to conducting business in a state. Investment adviser representative licensing is always handled at the state level. Investment adviser firms must review and determine that all investment adviser representatives are properly licensed prior to conducting business in a state.
September 06, 2018
The U.S. Securities and Exchange Commission (“SEC”) recently announced that it has settled charges with an investment adviser firm. The SEC alleged that the investment adviser failed to disclose a conflict of interest. The settlement ended in payment of $8.9 million to the SEC by the investment adviser.
On April 12, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) of U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert, “Overview of the Most Frequent Advisory Fee and Expense Compliance Issues Identified in Examinations of Investment Advisers.” The risk alert provides a list of compliance issues frequently identified in OCIE examination deficiency letters relating to fees and expenses charged by SEC registered investment advisers. Click here to read the SEC’s Risk Alert.