IAR Registration Requirements
Chapters in this video
- 0:00 No free-standing IAR registration: the rogue surgeon rule
- 1:58 State-registered IA vs federal covered adviser: where Ivan registers
- 2:36 The federal adviser trap: clients in three states, register in one
- 3:52 Who notifies Stan: firm paperwork or walk of shame
- 4:57 De minimis exemption: zero office plus five or fewer clients
- 6:01 The broom closet trap: why two clients still requires registration
- 6:50 Rapid-fire exam recap
What this video covers
- Why there is no free-standing IAR registration, and what happens to an IAR's registration the instant employment terminates
- The difference between a state-registered investment adviser (IA) and a federal covered adviser, and how each type determines where an IAR must register
- Why place of business is the sole trigger for IAR registration with a federal covered adviser, while clients plus place of business matter for state-registered IAs
- Who must notify the Administrator when an IAR begins or ends employment: the firm for state-registered IAs, the individual IAR for federal covered advisers
- The two mandatory conditions for the de minimis exemption: no place of business in the state, plus either institutional-only clients or five or fewer non-institutional clients in the preceding 12 months
- Why opening any office in a state instantly destroys the de minimis exemption regardless of client count
- Why exemption from registration never means exemption from the antifraud provisions of the Uniform Securities Act (USA)
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