Investment advisers and Investment Adviser Representatives operating in New York are subject to requirements administered by the New York Attorney General’s Investor Protection Bureau.
New York’s requirements deserve particular attention because advisers should not assume that registration rules are identical from one state to another.
When Is Registration Required in New York?
According to the New York Attorney General, registration or notice filing is generally required when an investment adviser or solicitor has six or more New York clients.
Firms seeking state registration file Form ADV through IARD. State applicants are required to submit the applicable parts of Form ADV and provide financial statements to the Office of the Attorney General.
Federally covered investment advisers can also have New York notice-filing obligations.
Investment Adviser Representatives
New York also requires qualifying individuals associated with advisory firms to register through the CRD system.
Depending on the individual’s role and circumstances, examination requirements can include the Series 65 or an appropriate Series 66 route. New York’s regulations also contain waiver provisions for certain qualifying individuals.
Advisers should therefore consider both the registration status of the firm and the status of the people actually providing advice.
Building a Documented Planning Process
Regulatory compliance extends beyond registration.
Financial professionals need systems for managing client information, disclosures, agreements and records relating to the advice they provide.
Asset-Map helps advisers organise a client’s financial household in a visual format, providing a structured way to capture and revisit important financial information.
For firms building a documented financial planning process, this can support more consistent client meetings and record keeping while the firm maintains its separate regulatory and compliance procedures.
This page is for general informational purposes and does not constitute legal or compliance advice.