IA Checklist

Missouri Investment Adviser Application Checklist

Missouri Securities Division Audit Unit Information

IA Switch Pre-Registration Exam Report

IA Switch Final Report

Presentation on IA Switch Issues

No Action Letter

No-Action Determination Concerning Private Fund Advisers

IA Switch Letter to IA Firms

December 2011 Letter to Switching Investment Advisers

Pension Administrators No-Action Letter

No-Action Determination on Pending Application at Switch Deadline

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 ( 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 (

December 15, 2011


Subscribe to the Missouri Securities Division e-newsletter.

  • September 6, 2012
    The Commissioner of Securities has issued an Advisory Release alerting Missouri's investment advisers and others to a recent report on the Investment Adviser Registration "Switch." Read the release here, and the Report here.

  • July 3, 2012
    The Commissioner of Securities has issued an Advisory Release concerning pending investment adviser registration applications after the Dodd-Frank Act "Switch" deadline. Read the release here.

  • May 17, 2012
    The Commissioner of Securities has issued an Advisory Release concerning a no-action letter and the April 26 rulemaking concerning Missouri Private Fund Advisers. Read the release here.

  • April 26, 2012
    The Commissioner of Securities has issued an advisory release concerning a rulemaking related to an exemption from registration for certain advisers to private funds. Read the release here.

  • March 23, 2012
    The Commissioner of Securities has issued an advisory release on the fast-approaching deadlines and best registration practices for investment advisers switching to state registration. Read the release here.

  • December 30, 2011
    The Commissioner of Securities sent a letter to Missouri Investment Advisers who may switch to state regulation in 2012 under the Dodd-Frank Act. Read the letter here .

  • December 15, 2011
    Advisory Release AR-11-07
    The Commissioner of Securities issued an advisory release summarizing NASAA’s coordinated review program for investment advisers switching to state regulation in 4-14 states. Read the release here.

  • July 20, 2011
    Advisory Release AR-11-04
    The Commissioner of Securities for the State of Missouri issued an advisory release summarizing a No-Action Determination issued in response to a request by an adviser to a private fund. Read the release here.

View all developments