Investment Adviser State Registration and De Minimus Exemption

April 2009

 

Current market events and economic downturns have created a domino effect for
investment advisers when it comes to registration requirements and annual updates. With
the recent passing of the March 31st SEC deadline for annual amendments to a firm's
Form ADV, more firms are realizing that they no longer qualify for registration with the
SEC. When assets under management fall below the required minimum a firm becomes
ineligible to maintain its registration with the SEC. In most cases, if a firm's AUM drops
under $25 million then it no longer qualifies for registration with the SEC and must look
to individual states for their separate requirements. So where does a firm begin when
starting a state registration?

 

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