Unit 10: Regulation of Investment Adviser Representatives Flashcards
Investment Advisor Representative
Represents the firm, is a natural person.
If sole-prop, IA and IAR are the same person
Excluded from IAR definition
Admin/Clerical work
Incidental Advice
Doesn’t regularly solicit and provide client specific advice
Exempt from IAR definition STATE
-de minimis, no place of business and T12 is 5 or under
-snowbird
Exempt from IAR definition FEDERAL
IAR only needs to register if there is a place of business
-principal office doesn’t matter
When IA registers in new state
the officers, partners, and directors functioning as IARs are automatically registered.
-supervisory principals are considered IAR’s too
IAR termination STATE
IA notifies admin promptly
IAR termination FEDERAL
IAR notifies admin promptly
update U4
IAR must update U4 within 30 days
renew registration
IA and IAR both renew on Dec 31st.
Section 203A
-IAR for federally covered does not need to register in a state with de minimis clients and no public place of business
-a quarterly seminar constitutes a place of business