Investment Adviser Registration

Money managers, investment consultants, and financial planners are regulated in the United States as “investment advisers” under the Investment Advisers Act of 1940 (“Advisers Act”) or similar state statutes.

 

Generally, investment advisers with at least $100 million of assets under management (AUM) must register with the SEC and those with less than $100 million of AUM must register with the applicable states. There are registration requirements (e.g. advisers to investment companies) and exemptions (e.g. family offices, advisers solely to private funds with less than $150 million AUM) not fully described here that we are happy to discuss.

  

After assessing the type of registration your firm needs, Cerulean will guide you through the entire registration process.

 

Our registration services include:

• WebCRD/IARD Entitlement Process

• Form ADV Part 1

• Form ADV Part 2A for the firm (disclosure brochure)

• Supplementary registration documents required by certain states

• Responses to applicable jurisdictions

• Form ADV Part 2B for representatives (brochure supplements)

• Form U4 for representatives

• Customized compliance manual

• Preparation of blotters and checklists for monitoring key procedures

• Incorporation of custodian reports into program

• Business Continuity Plan

• Code of Ethics (policy, forms and training)

• Privacy Policy and Notice

• Investment Management Agreement

• Applicable Solicitor Agreement

• Information Security Policy (template)

• Discussion (and if desired, drafting) of Anti-Money Laundering Policy

• Preparation of annual compliance calendar

• Implementation training session for the firm

 

After your registration is complete, Cerulean will follow up with you to see if you have any questions or need any additional services.