Investment advisers doing business in Florida may need to register with the Florida Office of Financial Regulation (OFR), depending on their regulatory status, activities and clients.
Florida distinguishes between state-registered investment advisers and federally covered advisers registered with the SEC.
Florida Investment Adviser Registration
State-covered investment advisers generally submit Form ADV through the Investment Adviser Registration Depository and pay the applicable state filing fee.
Florida also requires the registration of appropriate associated persons. The application process can involve Form U4, financial statements, organisational documents and, where required, fingerprints.
Florida currently provides a de minimis exclusion under which a firm may not be required to register with Florida if it has had fewer than six Florida-resident clients during the preceding 12 months. Advisers should check the complete requirements and exclusions before relying on this provision.
Florida Branch Offices
Florida has specific requirements concerning investment adviser branch offices.
A state-covered investment adviser’s Florida branch office generally needs to be notice filed. This is handled through Form BR and the CRD system, with applicable state fees.
That makes office location an important consideration for advisory firms expanding their physical presence in Florida.
Ongoing Requirements
Florida requires state advisers to keep Form ADV information current. Annual financial statements may also be required, depending on the firm’s circumstances.
Advisers therefore need a repeatable process for maintaining regulatory documents and accurate client information.
Asset-Map can support the client documentation side of that process by helping financial professionals organise household financial information and create a consistent visual record for financial planning conversations.
It should be used as part of the firm’s wider compliance and record-keeping processes rather than as a replacement for them.
This page provides general information and is not legal or compliance advice.