Mid-Sized Advisers: Guidance on Registration

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IA Compliance and Consulting is helping Mid-Sized Advisers Switch from SEC to State Registration

“Working with you to meet your investment advisor compliance needs”

Advisers that are between the $25 million and $100 million asset under management threshold in the United States will have to switch to state registration. Advisers will have until March 30 of next year to register with their state and until June 28 to complete the switch. The SEC adopted these rules on June 22, 2011 related to the registration of investment advisers with the SEC. This is in response to the changes that Congress passed in the Dodd-Frank Wall Street Reform and Consumer Protection Act. The SEC has provided a website with Frequently Asked Questions (FAQ’s) as promised in its main Dodd-Frank Rule. To visit the website go to: http://www.sec.gov/divisions/investment/midsizedadviserinfo.htm

All SEC-registered advisers that fall into this category will be required to file a Form ADV amendment and complete all items on the form to indicate with which regulator/state they should be registered between January 1, 2012 and March 30, 2012. However, if an adviser's state has not adopted an investment adviser statute (ie: state of Wyoming) or does not examine registered advisers (ie: state of New York) then the adviser may stay registered with the SEC, unless the adviser can fit within an SEC registration exemption, such as the venture capital fund adviser or the private fund adviser exemptions.

IA Compliance & Consulting can assist Advisers with these registration issues as well as any other compliance issues as needed. Suzette Surman and Karen Haggerty have almost 40 years of combined industry compliance service. They have extensive knowledge of the industry rules and regulations at both the SEC and state levels. For more information, please visit http/iacomplianceandconsulting.com or contact us at 832-559-8171.

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Suzette Surman

Karen Haggerty
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