State regulators today announced a coordinated review program for midsize investment advisers who will have to switch to state oversight.
The program is for investment advisers now registered with the Securities and Exchange Commission who must register with anywhere from four to 14 states, according to the North American Securities Administrators Association Inc.
Under the Dodd-Frank Act, advisers with $25 million to $100 million in assets under management must switch from federal to state registration by next June.
Advisers registered in 15 or more states can remain with the SEC.
“We’re hoping this [program] will smooth the whole process,” said Melanie Lubin, Maryland’s securities commissioner, who was involved in designing the program.
“A lot of this is just reconciling comments [advisory] firms get from states,” she said.
For example, Maryland advisers typically register in Washington, D.C., and Virginia, as well, Ms. Lubin said.
“They might get comment from a Virginia examiner that may or may not line up with a comment from one of mine,” she said. “This is just putting a [formal] process in place” to resolve deficiencies, Ms. Lubin said.
To participate in the program, advisers must submit a coordinated review form found at
NASAA’s Switch Resource Center website, as well as all required documents, such as ADV forms, client contracts and financial information. There is no cost for using the service.
A program manager will act as facilitator in coordinating state reviews, but final authority to approve applications remains with each state.
About 3,200 advisory firms are expected to move from federal to state registration.
Firms must notify the SEC by the end of March 2012 as to their eligibility to remain SEC-registered. That is also the deadline for enrolling in NASAA’s coordinated-review program.
