Registration and Post-Registration

What this video covers

• The AUM ladder that dictates state versus Securities and Exchange Commission (SEC) registration, including the mandatory $110 million SEC trigger and the optional $100 million eligibility band
• The $90 million/$110 million asymmetric buffer and why it prevents constant regulator switching, plus the 90-day and 180-day deadlines for moving up or down
• Why a mid-size adviser in New York must register with the SEC regardless of AUM, since New York does not examine or inspect state-registered investment advisers (IAs)
• Additional no-AUM SEC triggers: registered investment companies, business development companies (BDCs), internet-only advisers, pension consultants, and common-control arrangements
• Books-and-records retention: five years from fiscal year-end, with the first two years readily accessible at the principal office
• Form ADV Part 2 brochure delivery timing, the 48-hour state option versus the stricter SEC rule, and what the brochure supplement reveals about the individual investment adviser representative (IAR)
• Net worth minimums ($35,000 with custody, $10,000 with discretion only) and the rounding-up bond calculation to the nearest $5,000 increment
• Continuing education (CE) requirements: 12 credits annually, split 6 and 6 between products and practice versus ethics and professional responsibility, with at least 3 ethics credits in the ethics bucket