Access Person
Who Is an “Access Person” at an RIA? Because access persons can see what trades are being made or recommended before the public does, the rule requires them to report their personal securities holdings and transactions on a periodic basis — typically initial holdings reports, quarterly transaction reports, and annual holdings reports. At many advisory […]
Supervised Person
Who Is a “Supervised Person” at an RIA? The supervised person classification is broad by design — it captures essentially anyone acting under the firm’s direction in connection with investment advisory activities, not just those with client-facing titles. These individuals are subject to the firm’s code of ethics, recordkeeping obligations tied to their conduct, and […]
Promoter
What Is a Promoter Under the Marketing Rule? Under the previous cash solicitation rule, “solicitor” specifically referred to someone paid a fee for client referrals. The SEC’s New Marketing Rule broadened this into “promoter,” which also captures compensated endorsers such as influencers or affiliates who tout the firm’s services, not just traditional referral arrangements. Promoters […]
Chief Compliance Officer (CCO)
What Is a Chief Compliance Officer (CCO)? The Chief Compliance Officer (CCO) is responsible for designing, implementing, and testing the firm’s compliance policies, conducting the annual compliance review, and serving as the firm’s primary point of contact during regulatory examinations. The role can be filled by an owner, a dedicated employee, or an outsourced compliance […]
Control Person
Who Is a “Control Person” at an RIA? Control isn’t limited to majority owners — someone with a smaller ownership stake but significant influence over firm decisions, or an officer with broad authority, can also qualify as a control person. The SEC’s threshold guidance generally treats 25% or greater ownership as presumptive control, but the […]
Related Person
Who Is a “Related Person” at an RIA? Related persons commonly include affiliated broker-dealers, insurance agencies, law firms, or other businesses under common ownership with the RIA. Form ADV Part 1 requires firms to disclose these relationships in detail, and Form ADV Part 2 (the brochure) requires a plain-language explanation of any related person arrangements […]