The Securities and Exchange Commission has developed the following registration schedule for investment advisers in order to facilitate the transition between federal and state registration:
For Mid-Sized IAs Registered with the SEC as of Jan. 1, 2012:
- Mid-sized advisers registered with the SEC on July 21, 2011 must remain SEC registered until Jan. 1, 2012.
- File amendment to ADV between Jan. 1, 2012 and March 30, 2012.
- Mid-sized advisers no longer eligible for SEC registration must file ADV-W by June 28, 2012.
For “New” Mid-sized IAs:
- Until July 21, 2011 may register with either the SEC or appropriate state regulator.
- After July 21, 2011 must register with the appropriate state regulator (prohibited from SEC registration).
For IAs with AUM of $100 million or more:
- No change. Continue to register with SEC.