The Registration Process
Investment advisers whose assets under management exceed $100 million must register with the SEC.
In addition, the following additional advisers must also register with the SEC:
- • Advisers to registered investment companies
- • Advisers whose principal office and place of business is in a state that has not enacted an investment adviser statute (currently only Wyoming)
- • Pension consultants, if they provide investment advice with respect to $200 million or more of plan assets
Applicants for registration must file Form ADV (“ADV” = Adviser). Once registered, an adviser must update the form at least once a year. Form ADV consists of two parts. Part 1 requires applicants to provide information about the adviser’s business and its ownership, clients, employees, business practices, and any disciplinary events of the adviser or its employees. In 2011, the SEC expanded the information required, primarily by hedge fund advisers and other private funds. Amended Part 1A requires advisers to provide additional information about private fu