The Financial Reform bill signed into law by President Obama on July 21, 2010 changes the threshold for SEC registration of Investment Advisors to $100 million or more in regulatory assets under management for SEC Registered Investment Advisors.
If you are a mid-sized adviser registered with the SEC on July 21, 2011 you must maintain your SEC registration and comply with the Advisers Act until January 1, 2012, unless you file a “full withdrawal” on Form ADV-W to withdraw from registration in all of the jurisdictions with which you are registered (or have an application for registration pending). However, you may not switch to state registration until after January 1, 2012.
If you are registered or have an application for registration pending with the SEC on January 1, 2012, you must file an amendment to Form ADV no later than March 30, 2012. You must update your responses to all items including the reporting of your regulatory assets under management determined within 90 days of the filing. If you are no longer eligible for SEC registration, you must mark the appropriate question on Form ADV.
If you are no longer eligible for SEC registration you must timely withdraw your registration by filing Form ADV-W.
For more information on this process, please complete the adjacent form, or call us at (603) 292-6772.