Please forward this error screen to sharedip-132148193207. WHAT IS AN INVESTMENT ADVISER AGENT? A sole proprietor of an investment adviser is not an investment adviser connecticut investment adviser representative registration. Corporate officers and partners of a partnership may be investment adviser agents if they perform the functions of investment adviser agents.
Has more than five clients who are natural persons. Here, do not count the sophisticated natural clients described in the preceding paragraph. Fee payments are processed through the IARD. Every investment adviser agent registration expires on December 31st of each year unless renewed.
100 per investment adviser agent and is processed through the IARD. IARD if the investment adviser is a corporation, partnership or limited liability company. Section 36b-11 of the Connecticut Uniform Securities Act requires that each registration application include a photograph “unless the commissioner waives the requirement of such photograph. Commissioner has determined that a photograph is no longer required. Employer consent letters must have original signatures, be dated and signed by an officer, partner or other authorized person of similar rank.
Exception: No consent is needed where the employers are affiliated or under common management or control. An individual may be registered as an investment adviser agent with multiple investment advisers after receiving the department’s written consent. The undertaking may omit the joint and several liability component where the investment advisers are affiliated or under common management and control. If an investment adviser agent leaves your advisory firm’s employ, you must file written notice electronically with the IARD on Form U-5 within 30 days after the investment adviser agent’s departure. The notice should state why the investment adviser agent’s employment ceased. Instructions for Investment Adviser Agent Registration in Connecticut Abstract: Investment Adviser Agent Registration Instructions WHAT IS AN INVESTMENT ADVISER AGENT? What is a Federally Covered Investment Adviser?
A Federally Covered Investment Adviser or “FCA” is regulated by the SEC. 100 million in assets under management will be subject to state registration as a result of The Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. Does Connecticut Require FCAs to File a Notice as Permitted by NSMIA? Connecticut exempts FCAs from the registration requirements under the Connecticut Uniform Securities Act.
However, most FCAs must file a notice with the department if they wish to transact business in or from Connecticut. The notice is valid until December 31st of the calendar year in which it is first filed, and is renewable annually. Renewal notice filings expire on December 31st of the calendar year in which they are filed. What FCAs Do Not Have to File a Notice?
Certain FCAs do not have to file a notice with the department. FCA has had no more than five clients who are residents of Connecticut. Even though the FCA may be excused from filing a notice, the FCA must still consider whether it is engaging investment adviser agents who would have to be registered in Connecticut. FCAs relying on the de minimis exemption are encouraged to advise the department of that fact. How Are Clients Counted for Purposes of the State De Minimis Exemption? While an investment adviser having its principal office and place of business outside of the United States must count only clients that are United States residents, an investment adviser having its principal office and place of business in the United States must count all clients.
Broker-dealers whose performance of investment advisory services is solely incidental to the conduct of their broker-dealer business and who receive no special compensation for the advisory services. Connecticut Insurance Commissioner when providing services to separate accounts of the insurance company or registered investment companies all of whose shares are owned by the insurance company or its insurance company affiliates or by the separate accounts of the insurance company or its insurance company affiliates. Connecticut Uniform Securities Act falls on the FCA. Connecticut Uniform Securities Act need not register as investment adviser agents in Connecticut since their employing firm is not an “investment adviser” as defined under state law. Caution: The following analysis is subject to further review and change following July 21, 2011 effectiveness of The Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. Investment Advisers would technically be subject to state registration requirements.
Investment Advisers Act of 1940, neither a Connecticut registration nor a Connecticut notice would be required. Investment Advisers Act of 1940 since their advisory activities are regulated by state law. Connecticut Uniform Securities Act, individuals representing them in performing advisory or solicitation functions would not be “investment adviser agents” and would not have to register as such in Connecticut. What Type of Notice Must an FCA File? Part II of Form ADV need only be filed if the Commissioner specifically requests it. How Must FCAs Make Their Notice Filing and Remit Payment for Notice Filing Fees?
IARD participation by FCAs is mandatory for both initial and renewal notice filings in Connecticut. In addition, federal law requires that FCAs register with the SEC via the IARD system. IARD is capable of accepting Part 1 of Form ADV, Part 2 of Form ADV and investment adviser agent registration filings. FINRA requires that IARD filers pay participation fees separate and apart from notice filing fees required by the State of Connecticut, and that an account be established to fund state notice filing fee payments. In addition, users must be entitled to access the database.
For additional information on filing through IARD, see www. When Must an FCA Register its Investment Adviser Agents With Connecticut? Whether an FCA must register its investment adviser agents in Connecticut turns on an interpretation of federal law. While the department will not opine on whether a specific individual qualifies, the following summary provides general guidance. Investment adviser agent registration procedures can be found on the department’s web site.