Investment Advisor Registration

Compliance Advisor Professionals, LLC (CAP) partners with firms planning to register as an investment advisor with the United States Securities and Exchange Commission (SEC) or with state securities regulators. The regulator with which an investment advisor must register depends on the amount of assets under management (AUM). We offer our clients comprehensive guidance and service throughout the investment advisor registration process, whether federal or state.

Many of our clients spent years developing their skills and building a book of business under the auspices of a large corporate Registered Investment Advisor (RIA). They didn’t have to worry about registration, filings, or compliance; those details were managed by the larger entity. As they step out from that corporate umbrella to establish their own RIA, they become responsible for ensuring that their registration is complete and accurate.

CAP makes the process seamless and provides the support you need to be confident in registration documents. We ensure that you are not only registered, but examination-ready from day one.

Investment Advisor Registration Requirements

The investment advisor registration process includes the filing and construction of several documents to comply with SEC and/or state rules and regulations. The development of a Compliance Program is a critical part of the investment advisor registration requirements. We often refer to the Compliance Program as a “three-pegged stool.”

Disclosure Documents: The “Top of the Stool”

Disclosure documents, which include Form ADV Part 1, Form ADV Parts 2A and 2B, Form ADV Part 3, and Form U4 filings, as well as any firm marketing materials. All of these form the top of the “stool.” These disclosure documents are supported by three “pegs”; the better constructed they are, the sturdier and stronger the Compliance Program will be.

The Compliance Manual

The Compliance Manual is the first “peg” of the stool. This is the internal playbook for how the firm operates, covering issues such as standards of business conduct, trading practices, recordkeeping, billing, client communications, and more.

The Code of Ethics

The Code of Ethics is the second “peg” of the stool. It establishes the standards of personal conduct for the firm’s employees, addressing issues such as conflicts of interest, acceptance of payments or gifts, and political contributions, among others.

Security Plan

The third and final “peg” of the stool is security, outlined in three compliance documents: Written Information Security Plan, Incident Response Plan, and Business Continuity Plan. These documents address the maintenance of business operations during crises like natural disasters, cyber-attacks or other major events that could disrupt the firm’s usual operations.

Your firm’s Compliance Program isn’t just a series of documents; it is critical infrastructure. CAP works with you to build a registration package that is customized to your unique business, so it can serve as a well-constructed foundation for that business.

How CAP Helps with Investment Advisor Registration

Our team includes a CPA, a former Chief Compliance Officer, as well as a former state regulator, all with in-depth, hands-on experience with the registration process. We offer our clients as much support as they need throughout the registration process, walking them through each step, educating them, and making them partners in the process as we complete each filing and document on their behalf.

As with all of our services, we tailor our assistance to the needs of the individual client. We offer registration services as a complete package, on a fixed-fee basis. Clients who work with us on an ongoing basis after registration have the support of dedicated team members who know them and understand their business.

Our Complete Registration Package

CAP takes pride in ensuring that our clients have everything they need for a successful registration. Our complete registration package includes:

• Telephone consulting on compliance matters
• Obtaining entitlements for access to the Investment Advisor Registration Depository (IARD) system
• Preparation and filing of:
  • Form ADV Part 1
  • Form ADV Parts 2A, 2B, Form ADV Part 2A Appendix 1 (Wrap Fee Brochure), as applicable, and Form ADV Part 3 (Customer Relationship Summary)
  • Form U4 filings
  • Assistance with SEC inquiries or state regulatory inquiries
• Development of a customized Compliance Program, including:
  • Compliance Manual
  • Code of Ethics
  • Business Continuity Plan
  • Compliance Checklist
  • Written Information Security Plan
  • Incident Response Plan
  • Privacy Notice
• Review of marketing materials, as needed
• Compliance training for staff

We look forward to working alongside you to complete the Investment Advisor Registration process, and to offering customized support for your compliance needs going forward.