Investment Adviser Registration

Investment advisers must register with the SEC or state(s) depending on their assets under management and place of business.

Form ADV Overview

Form ADV is the uniform registration document for investment advisers, filed electronically through the IARD (Investment Adviser Registration Depository) system.

Form ADV Parts

Part 1 Contents

Part 1 includes detailed information for regulators:

• Identification and contact information
• Ownership and control persons
• Types of advisory services offered
• Other business activities
• Affiliates and arrangements
• Custody arrangements
• Financial industry activities
• Disciplinary history
• Bond/insurance information

Part 2A Brochure Contents

The brochure must disclose:

Part 2B Brochure Supplement

Required for each supervised person who:

• Provides investment advice to clients
• Has significant contact with clients
• Has discretionary authority

Must include:

• Educational background and business experience
• Disciplinary information
• Other business activities
• Additional compensation arrangements
• Supervision structure

Form CRS (Part 3)

Required for SEC-registered advisers serving retail clients:

• Maximum 2 pages (4 pages for dual-registrants)
• Plain-language format
• Relationship Summary header
• Key questions format
• Comparison of services (for dual-registrants)

Registration Timeline

Initial Registration

Ongoing Requirements

Brochure Delivery Requirements

Initial Delivery

Annual Delivery

Two options:

1. Full brochure - Deliver updated brochure within 120 days of fiscal year end
2. Summary of changes - Deliver summary with offer to provide full brochure

Brochure Supplement Delivery

Form CRS Delivery

Recordkeeping Requirements

Retention Periods

Required Records

• Advisory contracts
• Client communications (written)
• Trade confirmations and statements
• Financial statements
• Advertising materials
• Written supervisory procedures
• Code of ethics and acknowledgments

Access by Regulators

Advisers must make records available:

• During reasonable business hours
• For examination by state administrator
• Without prior notice required

Withdrawal and Termination

Voluntary Withdrawal

• File Form ADV-W through IARD
• Effective 30 days after filing (unless earlier order)
• May be delayed if investigation pending

Successor Registration

When ownership changes:

• Successor may file for registration
• Pending status during transition
• New registration required for material changes in control

Exam Tip: Brochure (Part 2A) must be delivered BEFORE or AT contract signing. Form ADV amendments for material changes are due within 30 days. Records must be kept 5 years, first 2 years at principal office.