Updating the Brochure

Timely Updating the Brochure

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

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Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure

Any RIA compensated under a wrap fee program for sponsoring, organizing, or administering the program, or for selecting, or providing advice to clients regarding the selection of, other investment advisers in the program, does not use the normal brochure or Part 2A of the ADV. Instead, that adviser furnishes clients and prospective clients Part 2A, Appendix 1.

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Brochure Delivery Requirements

Brochure Delivery Requirements

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 according to the brochure delivery requirements set in 17 CFR § 275.204-3 – Delivery of brochures and brochure supplements.

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Form ADV

Form ADV

Form ADV is the uniform form used by investment advisers that manage at least $25 million in assets to register with both the SEC and state securities authorities. The Form ADV is divided into 3 parts. Part 1 is a fill-in-the blank form that contains information about the investment advisory business and how it operates. Part 2 is a brochure in narrative form that include plain English disclosures of the adviser’s business practices, fees, conflicts of interest, and disciplinary information. The last part is Part 3, which contains the relationship summary, which investment advisers are required to deliver to retail investors that discloses certain information about the firm.

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Change to New York IAR Registration

Change to New York IAR Registration

On December 1, 2020, the state of New York adopted new regulations that amended its Investment Advisory Act to require the registration of investment adviser representatives (“IAR”) including principals, supervisors, and solicitors through the WebCRD/IARD system. Prior to the rule change, New York was the only state that did not license IAR via the WebCRD/IARD system. The change to to New York IAR registration will go into effect on February 1, 2021 for all new registrants, and December 2, 2021 for any New York IARs already providing services, provided they apply for registration by August 31, 2021. The Amendments The Read more about Change to New York IAR Registration[…]

Buying A Broker Dealer: Pros and Cons

Pros and Cons of Buying A Broker Dealer

Considerations for Buying a Broker Dealer

If you find yourself in need of a broker dealer, you have the option to either buy an existing one or start one from scratch. MasterCompliance has years of experience in both brokering broker dealer transactions as well as assisting our clients create new broker dealers, and in our experience buying a broker dealer tends to be the most popular choice. While the speed and convenience of buying a broker dealer are favorable, there are pros and cons to this option you should consider.

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