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Starting an RIA - Registration Paperwork


usdtor05
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I’m in the process of starting a new separately managed account RIA and trying to figure out all the paperwork to get registered and I wanted to see if anyone else has gone through this process and can offer some insight. I have less than $25M (now the limit is actually $100M in most states) in AUM so will be registering with the state of Washington, not the SEC.

 

Most sites, such as this one from IB (http://www.interactivebrokers.com/download/HowToBecomeRIA_Web.pdf) make it sound like after you set up your LLC and get an EIN (which I’ve done) then you simply register with FINRA through the IARD system, take the Series 65 if you don’t already have the 66 and 7 (I’m registered to take the 65 in a couple weeks), fill out your Form ADV and away you go. And if I go to the IARD website (www.iard.com) it says that the only thing I need to do to access the IARD system (and therefore the form ADV filing) is to fill out the State Registrant Entitlement Packet (http://www.iard.com/pdf/stateEntitlementPacket.pdf) and send it in and then I get access to the IARD system where I can electronically file my ADV.

 

However, when I go to FINRA’s site (http://www.finra.org/Industry/Compliance/Registration/MemberApplicationProgram/HowtoBecomeaMember/) it notes that I need to fill out the following 4 forms to be able to even get access to the Firm Gateway (which I believe is the same thing as setting up an account on IARD) where I can then fill out my ADV: 1) Notarized Form BD, 2) Super Account Administrator Entitlement Form, 3) Member Firm Email Notification Contact Form, 4) New Member Assessment Report. It also says that once I’ve been approved for access to the Firm Gateway, I need to fill out a very lengthy Form NMA before I can have an opportunity to file my Form ADV.

 

The Form BD is an application to become a Broker/Dealer, which is not what I’m doing, so it doesn’t make sense that I would need to fill that out to become an RIA right?

 

Even though FINRA’s website says I need to fill out those four forms, can anyone confirm that since I’m registering as an RIA I simply should be filling out the State Entitlement Packet at IARD and submitting it, and following the process as laid out on the IARD website rather than the process shown on the FINRA website?

 

Thanks for any insights! I searched the blogs but didn’t find a clear answer to this.

 

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I’m in the process of starting a new separately managed account RIA and trying to figure out all the paperwork to get registered and I wanted to see if anyone else has gone through this process and can offer some insight. I have less than $25M (now the limit is actually $100M in most states) in AUM so will be registering with the state of Washington, not the SEC.

 

Most sites, such as this one from IB (http://www.interactivebrokers.com/download/HowToBecomeRIA_Web.pdf) make it sound like after you set up your LLC and get an EIN (which I’ve done) then you simply register with FINRA through the IARD system, take the Series 65 if you don’t already have the 66 and 7 (I’m registered to take the 65 in a couple weeks), fill out your Form ADV and away you go. And if I go to the IARD website (www.iard.com) it says that the only thing I need to do to access the IARD system (and therefore the form ADV filing) is to fill out the State Registrant Entitlement Packet (http://www.iard.com/pdf/stateEntitlementPacket.pdf) and send it in and then I get access to the IARD system where I can electronically file my ADV.

 

However, when I go to FINRA’s site (http://www.finra.org/Industry/Compliance/Registration/MemberApplicationProgram/HowtoBecomeaMember/) it notes that I need to fill out the following 4 forms to be able to even get access to the Firm Gateway (which I believe is the same thing as setting up an account on IARD) where I can then fill out my ADV: 1) Notarized Form BD, 2) Super Account Administrator Entitlement Form, 3) Member Firm Email Notification Contact Form, 4) New Member Assessment Report. It also says that once I’ve been approved for access to the Firm Gateway, I need to fill out a very lengthy Form NMA before I can have an opportunity to file my Form ADV.

 

The Form BD is an application to become a Broker/Dealer, which is not what I’m doing, so it doesn’t make sense that I would need to fill that out to become an RIA right?

 

Even though FINRA’s website says I need to fill out those four forms, can anyone confirm that since I’m registering as an RIA I simply should be filling out the State Entitlement Packet at IARD and submitting it, and following the process as laid out on the IARD website rather than the process shown on the FINRA website?

 

Thanks for any insights! I searched the blogs but didn’t find a clear answer to this.

 

You don't need to become a member of FINRA. Everything before your paragraph beginning with the word "However" is what you need to do.

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Thanks. Tim that link is very helpful, surprised I hadn't stumbled across it yet. Do you guys know if I were to pay people (as third party consultants) to bring in clients for me if they would be required to pass the Series 65 as well (or meet one of the required exemptions such as CFA, CFP, etc.)?

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