Part 2A of the Form ADV requires advisers to create narrative brochures containing information about the advisory firm. Both federal and state registered advisers must prepare and deliver a brochure to their clients. They both also have requirements set by the SEC and NASAA for timely updating their brochure
As a registered adviser, you must make and keep true, accurate and current certain books and records relating to your investment advisory business. Federal covered advisers registered under section 203 of the Act (15 U.S.C. 80b-3) are required by the SEC to make and keep true, accurate and current books and records relating to its investment advisory business of the following:
For an investment adviser to qualify for an exemption from state registration, they have to either meet an exemption under the Investment Act of 1940, be a federal covered adviser, or be registered with the SEC. The Dodd-Frank Act has created 3 thresholds for investment advisers based of their assets under management (“AUM”) as well as some more general exclusions, all of which provide advisers the ability to register with the SEC.