This blog is a follow up to our Change to New York IAR Registration blog, and a reminder that the August 31st deadline to submit a waiver for registration to New York is looming.

Effective February 1, 2021, New York now requires Individuals to register in the state. Previously, NY has not held 65/66 licenses; however, this has changed. Note the registration standards for state-registered firms and SEC-registered firms differ.

State-Registered Firms

The new rule requires all investment adviser representatives with more than five clients in the state of New York to register as an investment adviser, unless exempt from registration. All principals, investment adviser representatives, supervisors, and solicitors must apply for registration in connection with their representation of any registered investment adviser. If your Firm does not have a place of business in NY but is registered or required to register in the state of NY (subject to de minimis requirements), any IARs with clients in NY will also require registration.

SEC-Registered Firms

All investment adviser representatives and solicitors for a federally covered investment adviser from a place of business in NY must apply for registration in connection with their representation. Firm principals and supervisors for an SEC-registered investment advisor with a place of business in the state of NY will now be required to register by amending or filing Form U4.

NY requires all registered persons to successfully pass the series 65 or 7/66. There are several waivers available, but they must be submitted no later than August 31, 2021. If an IAR is not eligible for a waiver, they will be required to take and pass an exam no later than December 2, 2021.

For more information on the changes, check out the (Unofficial) TEXT OF REVISED REGULATIONS (PDF download) from the New York State Office of the Attorney General.

Check out some of other blogs:

MasterCompliance provides expert consulting, outsourcing, and implementation tools in planning and budgeting for your firm’s compliance responsibilities. Also, if you have any questions about how this applies to your Firm or if your Firm has anyone subject to the new New York IAR registration, please contact us.