Post on 01-Jul-2015
The ConsortiumThe Consortium
The Consortium
ADV 2Workshop
RIA Central
January 19, 2010
Nancy Liningerwww.liftburden.com
The Consortium
From ADV II To 2From ADV II To 2
ADV I ADV 1
ADV II ADV 2
The Consortium
Working PartsWorking Parts
1A – online all advisors
1B – online state-registered
2A – Investment Advisor (“Firm”) Brochure
2A Appendix 1 – Wrap Fee Brochure
2B – Brochure Supplement Supervised Person
Summary Material Changes – 2A or separate
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Brochure Supplement – 2BBrochure Supplement – 2B
Brochure supplement for the following supervised persons:
Any supervised person who formulates investment advice for a client and has direct client contact; and
Any supervised person who has discretionary authority over a client’s assets even if the supervised person has no direct client contact.
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Brochure Supplement – 2BBrochure Supplement – 2B
Part 2B may be combined with Part 2A.
May prepare a group supplement.
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Summary Material ChangesSummary Material Changes
Identify and discuss changes:
on the cover page of the brochure or
on the page immediately following the cover page,
or as a separate document accompanying the brochure.
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Summary Material ChangesSummary Material Changes
Within 120 days of your fiscal year end deliver your annual Summary of Material Changes if there have been material changes since the last annual updating amendment.
Delivery of Summary Material Changes may be:(1) a free updated Firm Brochure that either
includes a Summary of Material Changes or is accompanied by a separate document Summary of Material Changes, or
(2) just the Summary of Material Changes that includes an offer to provide a copy of the updated Firm Brochure, and information on how a client may obtain the Firm Brochure.
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Delivery RequirementsDelivery Requirements
Part 2A
Initial Delivery
Annual Delivery
Interim Delivery
Part 2B
Initial Delivery
Annual Delivery
Interim Delivery
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Electronic DeliveryElectronic Delivery
Notice to clients
Access by clients
Evidence of delivery
www.sec.gov/rules/concept/33-7288.txt
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Ugh! Where Do I Start?Ugh! Where Do I Start?
1. Blank white screen in WORD
2. NASAA ADV 2 template with section headings: http://www.nasaa.org/industry___regulatory_resources/investment_advisers/758.cfm
3. SEC IARD website instructions & section headings: http://www.sec.gov/about/forms/formadv.pdf
4. The Consortium ADV 2 template with headings, instructions, and sample narrative: www.ADV2compliant.com
The Consortium
Main headings in order – 2A:Main headings in order – 2A:
Cover PageMaterial Changes Table of ContentsAdvisory business Fees and compensationPerformance-based fees and side-by-side management Types of ClientsMethods of analysis, investment strategies, and risk of lossDisciplinary information Other Financial Industry Activities and AffiliationsCode of ethics, participation or interest in client transactions, and personal tradingBrokerage practices Review of AccountsClient Referrals & Other CompensationCustodyInvestment DiscretionVoting Client SecuritiesFinancial InformationRequirements for State Registered Advisers
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Main headings Part 2B:Main headings Part 2B:
Cover PageEducational Background and Business ExperienceDisciplinary Information Other Business ActivitiesAdditional CompensationSupervisionRequirements for State Registered Advisers
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The most challenging itemsThe most challenging items
Part 2A Item 8 Risk of Loss Item 9 Disciplinary History (if any)
Part 2B Item 2 Professional Designations qualifications
http://apps.finra.org/DataDirectory/1/prodesignations.aspx
Item 3 Disciplinary History (if any) Item 6 Supervision
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How long will this take?How long will this take?
Write from scratch?
Using a template?
Cut and paste from your
existing computer
document?
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IARD UploadIARD Upload
Log onto IARD: https://crd.finra.org/iad Filing type:
Annual updating amendment or
Other than annual amendment
Prepare all ADV Part 1 updates first & execution pages
Left-hand navigation panel: Part 2 hyperlink
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IARD UploadIARD Upload
Complete fields for: Brochure name (e.g., [RIA name] Part 2 [date]) Brochure types (Individuals, Pension Plans...) Brochure description is not a required field
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IARD UploadIARD Upload
Part 2 from navigation panel (yes, again)
Submit filing from navigation panel (you still have not uploaded your ADV 2!)
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IARD UploadIARD Upload
All completeness check errors must be cleared prior to submission
Click browse to locate your document on your computer.
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IARD UploadIARD Upload
Locate your document and click open.
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IARD UploadIARD Upload
Don’t stop short... Warning screen opens – click OK Another screen displays – click OK again
If successful, the ADV new filing screen opens.
But you are done and you can exit.
Anything you wanted to know about IARD filing
at the Users Manual:
http://www.iard.com/pdf/firm_users_man.pdf
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More to think about:More to think about:
Advisory Agreement
Written Supervisory Procedures
PR / Marketing Brochure
Website
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Links to more informationLinks to more information
Adopting Release Form ADV Amendmentshttp://www.sec.gov/rules/final/2010/ia-3060.pdf
ADV 2 Instructions from SEC IARD website
http://www.sec.gov/about/forms/formadv-part2.pdf SEC Division of Investment Management IARD Home Page
http://www.sec.gov/divisions/investment/iard.shtml FINRA Sponsored IARD Home Page (IARD Administrator)
http://www.iard.com/ NASAA IA Switch Center (State Securities Administrators)
http://www.nasaa.org/industry___regulatory_resources/investment_advisers/13183.cfm
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Phone #’s and websitesPhone #’s and websites
FINRA IARD (IA Firms) (240)386-4848www.iard.com
FINRA/CRD (BD Firms) (301)590-6500www.finra.org/RegulatorySystems/CRD/index.htm
SEC IARD (opinions) (202)551-6999www.sec.gov/iard
State Securities Contact (link on “Find Regulator”)www.nasaa.org
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Full DisclosureFull Disclosure
Full disclosure is simply
telling clients about your
services, fees, and
conflicts.
Full disclosure is good
customer service.
The ConsortiumThe Consortium
The Consortium ADV 2
Workshop
RIA Central
January 19, 2010
Nancy Liningerwww.liftburden.com