Many registered investment advisers, through either affiliated or unaffiliated broker/dealer firms, develop and implement individualized money management programs. These programs can be referred to by several different names such as asset allocation programs, asset management programs, investment management programs, mini-accounts, and separately managed accounts. Regardless of the name used to describe a program, registered investment adviser firms must analyze their programs to determine if the program falls under the U.S. Securities and Exchange Commission’s (SEC) definition of “wrap-fee program”. Investment advisory programs meeting the definition of wrap-fee program are subject to additional disclosure requirements under Rule 204-3(f) of the Investment Advisers Act of 1940.
The following information is intended to provide guidance and a general overview regarding some of the more common issues relating to wrap-fee program disclosure issues and Rule 204-3(f). However, this webpage is not intended to be an all-encompassing analysis of wrap-fee program issues, and you should not solely rely on the contents of this page to determine if your registered investment adviser is the sponsor of a wrap-fee program. For an individualized consultation regarding the programs offered by your firm, please contact us to find out more about our Form ADV Part 2 Appendix 1 Wrap-Fee Disclosure Brochure consultation services.