Registration Schedule for Switching Firms

The Securities and Exchange Commission has developed the following registration schedule for investment advisers in order to facilitate the transition between federal and state registration:

For Mid-Sized IAs Registered with the SEC as of Jan. 1, 2012:

  • Mid-sized advisers registered with the SEC on July 21, 2011 must remain SEC registered until Jan. 1, 2012.
  • File amendment to ADV between Jan. 1, 2012 and March 30, 2012.
  • Mid-sized advisers no longer eligible for SEC registration must file ADV-W by June 28, 2012.

For “New” Mid-sized IAs:

  • Until July 21, 2011 may register with either the SEC or appropriate state regulator.
  • After July 21, 2011 must register with the appropriate state regulator (prohibited from SEC registration).

For IAs with AUM of $100 million or more:

  • No change. Continue to register with SEC.
Industry Resources, Investment Adviser