COMPLIANCE

Initial Consulting & IARD System Setup

IARD is the electronic filing system used to register investment advisers, perform regulatory reviews, file reporting adviser exemptions, and manage the public disclosure of information regarding RIAs. Engaging with IARD has its own complexities, but we are prepared to manage this step for you. Assure consults with each client regarding ERA and RIA filing implications and sets up IARD login credentials and an IARD account on behalf of its clients. If you have any questions regarding this process, our experts at Assure Services can give you direction and answers. What is the difference between ERAs and RIAs? The main difference between these two financial advisors can be found in their registration status. RIAs are registered with the SEC--the U.S. Securities Exchange Commission--or with state regulators. Whereas ERAs are exempt from such registration. ERAs, though exempt from registration, are still required to pay their fees and report public information through the IARD system. What kind of exemptions are available to ERAs? First, there is the private fund advisor exemption. In order to qualify, U.S. based advisors can only manage private funds and have less than $150 million in regulatory assets under management (AUM). For non-U.S. Advisors, they must ensure that their U.S. clients are only private funds. In these situations, only U.S. assets managed by the company contribute to the $150 million limit set by the SEC. Second, advisors can apply for a venture capital advisor exemption. In most instances, advisors managing solely venture capital funds can qualify for this particular exemption. Unlike with the private fund exemption, the advisor’s AUM is not a deciding factor. How can we help? We will make certain that this process is as smooth as possible for you. In order for an investment advisor to successfully receive either exemption, the ERA filing must be completed within 60 days of claiming the exemption. The date of claiming the exemption is usually the date on which the advisor begins managing the fund in question. Our job is to take care of this process for you. We will help you determine the best exemption for your situation and then ensure that your paperwork is properly filled out and filed with IARD on time. If you were to take on any separately managed accounts (SMAs) and subsequently lose your exempt status, then we will also manage your prompt registration with either the SEC or the state regulators.

Filing of Form ADV

RIAs and ERAs must file a completed Form ADV with the SEC. Assure provides accurate, complete, and timely filing and services related to the following:

IARD System Maintenance

Assure pays account, state and federal filing fees. Assure also maintains login credentials and manages user profiles.

Ongoing Compliance Consulting

Assure is available to train ERAs and RIAs regarding applicable SEC rules and guidelines, internal policy requirements, potential SEC audits, and triggers for non-annual amendments to Form ADV.

Contact us to learn to learn more about our services.