You can also search for an individual investment adviser representative and view that individual’s professional background and conduct, which includes current registrations, employment history, and disclosures about certain disciplinary events involving the individual. For instance, all SEC-registered investment advisers are required to have a written policy in location relating to the following subjects: insider trading, privacy, proxy voting (if the adviser has the authority to vote client proxies), and code of ethics.
Again, we propose that an investment advisor firm retain a compliance specialist or attorney that can take into account all of the information surrounding the firm’s circumstance in order to determine irrespective of whether an investment advisor registration exemption applies to the firm.
The SEC does not charge an initial or annual investment advisor registration renewal charge on the other hand, SEC firms failing to file their Annual Type ADV Element 1 Amendment in a timely fashion could have their investment advisor registrations withdrawn.
If a firm registers with the SEC as an investment advisor, but does not obtain $one hundred million in AUM inside 120 days, the firm must deregister as an investment advisor with the SEC and transfer its investment advisor registration to the state securities regulator.
The firm’s Policies and Procedures manual is the guiding document that your firm will use to keep and enforce your firm’s internal policies on all aspects of your small business from the handling of client complaints to the training of new Investment Adviser Representatives.