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Typically, the level of net worth, net capital or amount of bond is based on the procedures of the investment advisor firm.A common approach many state securities regulators have adopted is to require an investment advisor firm with custody of client funds and/or securities to maintain a net worth in the amount of ,000; an investment advisor firm maintaining discretionary authority, but not custody, over client funds and/or securities must maintain a net worth in the amount of ,000; and an investment advisor firm not meeting the net worth requirement often must then attain a surety bond in the amount of the net worth deficiency rounded plus ,000.Most state securities regulators require state registered investment advisor firms to maintain and enforce written procedures which set forth the procedures adopted by the firm in order to comply with the state’s rules and regulations and properly supervise its associated persons.Firms registering as an investment advisor directly with a state securities regulator will likely be subject to a net worth/net capital and/or bonding requirement.A staff summary of changes adopted to Form ADV Part 1A that were implemented on October 1, 2017 is available here: https://gov/rules/final/2016/ia-4509Q: What are the fees for advisers registering/registered with the SEC filing on IARD?
The Commission has approved the initial report and annual IARD filing fees for Exempt Reporting Advisers filing reports with the Commission (see Release No. Exempt Reporting Advisers will have to pay the fee associated with their initial reports with the Commission filed on or after November 7, 2011.A: The fee for initial reports and each annual updating amendment is 0 for Exempt Reporting Advisers.No fee is charged for filing an electronic amendment to Form ADV unless it is an annual updating amendment.A list of state filing fees can be found on com or you can call the appropriate states securities authority for state filing fee information.(Updated September 29, 2017) Q: I am a pension consultant who relies on Rule 203A-2(a) under the Investment Advisers Act of 1940 to register with the SEC. A: Your fees are based on regulatory assets under management, even if your regulatory assets under management are not the basis of your eligibility for SEC registration.