Securities Advisory Releases
Advisory Release AR-11-07:
NASAA’s Coordinated Review Program Available for Switching Missouri Investment Advisers
The Commissioner of Securities is issuing this advisory release to alert Missouri’s investment advisers of the Missouri Securities Division’s (“Division”) participation in the recently launched coordinated review program for investment advisers switching from federal to state oversight as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).
Previous to the Dodd-Frank Act, investment advisers with assets under management between $25 million and $100 million (“mid-sized investment advisers”) were federally registered and regulated. Beginning in 2012, those mid-sized investment advisers are required to register in, and will be regulated by, states where they transact business.
Created by the North American Securities Administrators Association (“NASAA”), the coordinated review program facilitates a concurrent states’ review of investment adviser applications submitted to multiple jurisdictions. Consequently, the program will provide a forum for states to discuss and evaluate registration applications while also easing the regulatory transition of mid-sized investment advisers applying in multiple states.
As a participant in this program, the Division will partner with other state regulators to provide Missouri’s mid-sized investment advisers a uniform and expedited registration process.
The coordinated review program is available for mid-sized investment advisers registering in 4 to 14 states (advisers registered in 15 or more states are permitted to remain federally registered).
How to Enroll
Eligible investment advisers can enroll in the program by submitting to NASAA the Coordinated Review Form found on NASAA’s website (www.nasaa.org). This submission should be made after filing, through the Investment Adviser Registration Depository system, all materials required for application for registration by each state in which the adviser is applying.
Once the applying adviser has submitted all the required application materials, the states will conduct a coordinated review of the adviser’s registration application. During their review, the states will identify and inform applicants of any application deficiencies. After the deficiencies are cured, and the states finish the review process, the adviser will be approved for registration.
There is no additional cost to participate in program, but advisers remain subject to the filing fees required for application in each state. The program concludes on March 30, 2012.
For more information about the Coordinated Review Program, visit the IA Switch Resource Center on NASAA’s website (www.nasaa.org).
December 15, 2011