I have assisted numerous financial industry professionals with their transition from the wire-house channel to operating as independent investment advisers. To do so takes experience, legal know-how, preparation, and patience. While other compliance companies can offer to register an investment adviser for a very small fee, I always caution prospective clients to be wary ofContinue reading “Registered Investment Adviser Entity Formation, Registration and Employment Transition Checklists”
Tag Archives: investment adviser
Logistical Wrinkles Relating to Form CRS
The rules and form implementing Form CRS became effective on September 10, 2019, and investment advisers and broker-dealers are currently in the early stages of preparing and developing internal procedures to comply with the rule and the form. By June 30, 2020, investment advisers registered with the U.S. Securities and Exchange Commission and broker-dealers willContinue reading “Logistical Wrinkles Relating to Form CRS”
SEC Considering Proposal to Amend the Advertising Rules
My thoughts on the new Advertising Rule Back in March 2019, Mark Schoeff from InvestmentNews reported that the U.S. Securities and Exchange Commission (“SEC”) was contemplating amending Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Advertising Rule”) . Before that, Reuters made a similar report in March. Before that, the Investment Adviser AssociationContinue reading “SEC Considering Proposal to Amend the Advertising Rules”
Trusted Contact Persons and Sample Form
Investment advisers and broker dealers and other persons in relationships of trust that must keep confidential a client’s contact information and wishes must be able to go outside of that circle of trust from time to time. However, laws such as Regulation S-P prohibit them from doing so. That is why many investment adviser inContinue reading “Trusted Contact Persons and Sample Form”
Payments of Transaction-Based Compensation by FINRA Members – An Update for Selling Groups and Individual Service Corporations and New Interpretive Guidance on the Horizon?
Back in December 2014, the Securities and Exchange Commission (“SEC”) approved a Financial Industry Regulatory Authority (“FINRA”) rule governing transaction-based payments to unregistered persons. The FINRA rule—Rule 2040—became effective on August 24, 2015. I understand that FINRA is currently considering providing members and the industry with written guidance so that their registered representatives can receiveContinue reading “Payments of Transaction-Based Compensation by FINRA Members – An Update for Selling Groups and Individual Service Corporations and New Interpretive Guidance on the Horizon?”
Form ADV Annual Amendment Updates: Best Practices and Recent Trends in Completing Form ADV
Here is a discussion on completing Form ADV and submitting annual updating amendments. We discuss: the timeline for submitting annual updating amendments, how to collect data, seeking input from operations and business units, taking positions on ambiguous questions, identifying conflicts of interest and adequately disclosing them, and recent trends in Form ADV Part 2A disclosure.
Financial Professionals Should Consider their Available Employment Options, Including Going Independent
Are you a financial adviser, investment adviser, wealth manager, registered representative or similar financial professional? There are many different names for those who render investment advice. Have you ever wondered how your clients’ situations might improve by changing your employer or business partner? Have you ever considered how your own personal financial well-being might improve if youContinue reading “Financial Professionals Should Consider their Available Employment Options, Including Going Independent”
California Assembly Bill 5 and the (Non-)Impact on the Financial Services Industry
California Assembly Bill 5 (the “Bill”) was passed in Senate on September 9, 2019 after passing the Assembly back in May. According to reporting by the New York Times, it is expected that California Governor, Gavin Newsom, will sign the bill. The Bill changes the status quo on the classification of employees and independent contractors.Continue reading “California Assembly Bill 5 and the (Non-)Impact on the Financial Services Industry”
Top 10 Considerations for Starting Your RIA
The following are the top ten considerations to make for starting an investment adviser: 1. You will want to develop and complete your firm’s business plan. You will need to decide on your resignation date and begin to develop your vision and strategy. It may be helpful to consider your existing clients, your strengths, your desiredContinue reading “Top 10 Considerations for Starting Your RIA”