![IARD 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](https://image.slidesharecdn.com/adv2workshop1-110121093203-phpapp02/85/Form-ADV-2-Workshop-16-320.jpg)
Form ADV 2 Workshop
- 1. ADV 2 Workshop RIA Central January 19, 2010 Nancy Lininger www.liftburden.com
- 2. From ADV II To 2 ADV I ADV 1 ADV II ADV 2
- 3. Working 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
- 4. Brochure 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.
- 5. Brochure Supplement – 2B Part 2B may be combined with Part 2A. May prepare a group supplement.
- 6. Summary 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.
- 7. Summary 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.
- 8. Delivery Requirements Part 2A Initial Delivery Annual Delivery Interim Delivery Part 2B Initial Delivery Annual Delivery Interim Delivery
- 9. Electronic Delivery Notice to clients Access by clients Evidence of delivery www.sec.gov/rules/concept/33-7288.txt
- 10. Ugh! Where Do I Start? Blank white screen in WORD NASAA ADV 2 template with section headings: http://www.nasaa.org/industry___regulatory_resources/investment_advisers/758.cfm SEC IARD website instructions & section headings: http://www.sec.gov/about/forms/formadv.pdf The Consortium ADV 2 template with headings, instructions, and sample narrative: www.ADV2compliant.com
- 11. Main headings in order – 2A: Cover Page Material Changes Table of Contents Advisory business Fees and compensation Performance-based fees and side-by-side management Types of Clients Methods of analysis, investment strategies, and risk of loss Disciplinary information Other Financial Industry Activities and Affiliations Code of ethics, participation or interest in client transactions, and personal trading Brokerage practices Review of Accounts Client Referrals & Other Compensation Custody Investment Discretion Voting Client Securities Financial Information Requirements for State Registered Advisers
- 12. Main headings Part 2B: Cover Page Educational Background and Business Experience Disciplinary Information Other Business Activities Additional Compensation Supervision Requirements for State Registered Advisers
- 13. The 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
- 14. How long will this take? Write from scratch? Using a template? Cut and paste from your existing computer document?
- 15. IARD 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
- 16. IARD 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
- 17. IARD Upload Part 2 from navigation panel (yes, again) Submit filing from navigation panel (you still have not uploaded your ADV 2!)
- 18. IARD Upload All completeness check errors must be cleared prior to submission Click browse to locate your document on your computer.
- 19. IARD Upload Locate your document and click open.
- 20. IARD 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
- 21. More to think about: Advisory Agreement Written Supervisory Procedures PR / Marketing Brochure Website
- 22. Links to more information Adopting Release Form ADV Amendments http://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
- 23. Phone #’s and websites FINRA IARD (IA Firms) (240)386-4848 www.iard.com FINRA/CRD (BD Firms) (301)590-6500 www.finra.org/RegulatorySystems/CRD/index.htm SEC IARD (opinions) (202)551-6999 www.sec.gov/iard State Securities Contact (link on “Find Regulator”) www.nasaa.org
- 24. Full Disclosure Full disclosure is simply telling clients about your services, fees, and conflicts. Full disclosure is good customer service.
- 25. ADV 2 Workshop RIA Central January 19, 2010 Nancy Lininger www.liftburden.com