The Investment Adviser Transition to State Registration
What is the IA Switch? The "switch" is part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which was signed into law on July 21, 2010. The Dodd-Frank Act made significant changes to the federal registration provisions for investment advisers and will require many firms to "switch" their registration from the U.S. Securities & Exchange Commission (“SEC”) to state securities registration.
Which firms are affected? The "switch" will affect many Missouri-based investment advisers, including some who are currently federally registered and others who are currently exempt from both federal and state registration. Investment advisers will be responsible for determining how the "switch" will affect them, and both the SEC and Missouri are providing guidance to assist investment advisers in making this determination.
When do firms switch? The SEC will issue rules establishing the dates by which certain key steps must be taken. The rules establishing these dates are likely to be published prior to July 21, 2011. View the chart below for information on the Key Steps.
Key Steps for Transitioning Investment Advisers
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May 17, 2012
The Commissioner of Securities has issued an Advisory Release concerning a no-action letter and the April 26 rulemaking concerning Missouri Private Fund Advisers. Read the release here. -
April 26, 2012
The Commissioner of Securities has issued an advisory release concerning a rulemaking related to an exemption from registration for certain advisers to private funds. Read the release here. -
March 23, 2012
The Commissioner of Securities has issued an advisory release on the fast-approaching deadlines and best registration practices for investment advisers switching to state registration. Read the release here. -
December 30, 2011
The Commissioner of Securities sent a letter to Missouri Investment Advisers who may switch to state regulation in 2012 under the Dodd-Frank Act. Read the letter here
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December 15, 2011
Advisory Release AR-11-07
The Commissioner of Securities issued an advisory release summarizing NASAA’s coordinated review program for investment advisers switching to state regulation in 4-14 states. Read the release here. -
July 20, 2011
Advisory Release AR-11-04
The Commissioner of Securities for the State of Missouri issued an advisory release summarizing a No-Action Determination issued in response to a request by an adviser to a private fund. Read the release here.