What Is the Filing Requirement for a Registered Investment Adviser?

A registered investment adviser is a financial professional that is licensed by state or federal agencies to provide advice regarding financial products for compensation. In order to become a registered investment adviser, you must check with your state securities regulators to determine what documents or financial regulations are specific to your case. Once you become an RIA, you must file amendments with the appropriate regulatory authorities on a regular basis.

Initial Application

In order to receive initial approval as an RIA, you must complete Form ADV, the Uniform Application for Investment Adviser Registration. All filings must be done electronically via the Investment Adviser Registration Depository. Advisers must register with the U.S. Securities and Exchange Commission once they manage at least $25 million of client assets. Other advisers register with their individual state. Regulators typically take three to four weeks to review Form ADV filings and respond to advisers with approval or denial.

Annual Amendments

Once you are approved as an RIA, you must make annual filings with the appropriate regulators via the IARD website. Within 90 days of the end of your fiscal year, you must electronically file an amendment updating all of the information included in your Form ADV. Typical adjustments to report include the number of clients you have, your assets under management, and any additional services you provide or no longer offer.

Other-Than-Annual Amendments

Any time there is a material change in the operation of your business as an RIA you must file an amendment with regulators via IARD. Examples of reportable changes include changes in address or key personnel, changes in fees charged or any criminal complaints lodged against the firm.

Representative Filings

In addition to filing a registration as an RIA, regulators require you to file information on any investment adviser representatives or IARs you have working at your firm. Regulators need at least one contact person at a firm, so if you are the only member of your RIA, you must report as an IAR. As with any financial representative, you must report on the qualifications of the IAR in terms of passing the appropriate licensing exams and provide the disciplinary record of the individual IAR.

References

• California Department of Corporations: Information to Assist Persons Applying for an Investment Adviser Certificate
• RIA Compliance Consultants: Frequently Asked Questions About Investment Adviser Registration
• U.S. Securities and Exchange Commission: Form ADV
• Investment Adviser Registration Depository: What Follows Once You Have an IARD Account
• U.S. Securities and Exchange Commission: Form ADV