Florida Investment Adviser Registration Requirements

General RIA Firm Registration Requirements:

FINRA Entitlement Paperwork

For an individual to file a registered investment advisor application with the State of Colorado, they must first apply to the Financial Industry Regulatory Authority (FINRA) to create an account (Entitlement) for their WebCRD/IARD online system (the web application for the registration of RIA and its representatives). FINRA does not regulate or supervise RIAs, but the State of Colorado uses FINRA’s WebCRD/IARD system to process applications.

Form ADV Part 1 (Online)

The Form ADV Part 1 is the online component to your Firm’s registration application. Note: The Form ADV Part 1 primarily discloses information about the firm. Individual information is primarily disclosed in Form U4 as detailed below. There are two parts to the Part 1. Part 1A is for all RIAs (both SEC registered and state registered), and Part 1B is specific to state registered advisors. The Form ADV Part 1 is also the vehicle to upload your Firm’s Form ADV Part 2A (Firm Brochure) and Form ADV Part 2Bs (Brochure Supplements).

Form ADV 2A (Paper and Online)

The Form ADV Part 2A acts as your Firm’s Disclosure Brochure. It is a narrative description of your services, fees, disciplinary disclosures, as well as several other firm details. The Form ADV Part 2A must be provided to all Clients and Prospective Clients. The State of Colorado requires that the Form ADV Part 2A be written in “plain English” and easily understood by your clients.

Form ADV 2B (Paper and Online)

The Form ADV Part 2B is the paper brochure that IARs must (in most cases) provide to clients. This form contains employment, educational, conflict of interest, and disciplinary information for each IAR. Generally, Executive Officers, any person generating investment advice provided to clients, anyone selling or soliciting investment advice for the RIA, and any representative advising clients must have a Form ADV Part 2B.

Client Advisory Contract

Client Advisory Contract including the appropriate regulatory authority standards for client advisory contracts in the State of Colorado.

Policies and Procedures Manual

The firm’s written Policies and Procedures manual is the guiding supervisory document that your firm will use to maintain and enforce your firm’s internal policies on all aspects of your business, from the handling of client complaints to the training of new IARs. It also houses your firm’s other policies, including but not limited to, Business Continuity Plan, Information Security Policy, Proxy Voting Policy, and Insider Trading Policy.

Privacy Policy

The Firm’s Privacy Policy must be provided to all clients at the beginning of the client relationship and annually thereafter. It must disclose how the firm stores, handles and disseminates client information. The Privacy Policy is built to your firm’s specifications and designed to meet State of Colorado compliance requirements.

Code of Ethics

Code of Ethics ensuring the firm upholds the fiduciary standards required by the State of Colorado.