In light of the new investment adviser representative (“IAR”) licensing requirement of the State of New York, RIA Compliance Consultants has updated its sample compliance manual section for investment adviser representative licensing in New York.
February 16, 2021
The State of New York recently announced a special exam waiver window on the Central Registration Depository (“CRD”) system, which will affect existing investment adviser representatives (“IARs”) seeking registration in New York via an exam waiver (in lieu of taking and passing the Series 65 or Series 66 & 7 examinations). IAR applicants requesting an exam waiver should apply between February 27, 2021 and August 31, 2021 in order to avoid opening an unnecessary exam window on the CRD system and being charged an examination fee. Between Feb. 27, 2021 and August 31, 2021, FINRA will temporarily modify the CRD system for NY only RA registration requests to allow the applicants who qualify for an exam waiver to avoid opening a window.
The State of New York’s new investment adviser representative (“IAR”) registration requirements are now effective. Prior February 1, 2021, New York remained the final state that did not require investment adviser representatives to be licensed with the state securities regulator by filing the Form U4. Adopted in December 2020, the rule changes now require the registration of investment adviser representatives – including principals, supervisors and solicitors for registered investment adviser firms – by filing the Form U4 via the WebCRD/IARD system. Registration is required for investment adviser representatives of New York state registered investment adviser firms, as well as for investment adviser representatives of SEC-registered investment adviser firms, if the investment adviser representative conducts advisory activities from a place of business in New York.
December 07, 2020
In December 2020, the New York Attorney General’s Investor Protection Bureau (IPB) adopted proposed rule changes to 13 N.Y.C.R.R. Part 11. These rule changes require the registration of investment adviser representatives – including principals, supervisors and solicitors for registered investment advisers – through the WebCRD/IARD system beginning February 1, 2021. Prior to the rule change, New York was the only state that did not license investment adviser representatives via the WebCRD/IARD system. Click here to read the final adopted rule.