Investment Adviser Switch FAQ
Q What is a mid-sized adviser?
A A mid-sized advisor is a firm with AUM of $25 to $100 million.
Q What is a Switch Firm?
A A Switch Firm is a mid-sized adviser that will be transitioning from SEC to State registration due to regulatory changes enacted through the Dodd-Frank act.
Q When can I apply for registration in Vermont?
A Switch Firms can begin applying immediately for Vermont registration.
Q What is required of my Switch Firm to receive registration approval in Vermont?
A To apply for registration in Vermont, you must provide the information and documentation listed on the Division's State Registered Investment Adviser page.
Q What is the cost to apply for Vermont registration?
A The cost for registration is $250 and will be paid through IARD.
Q When must my Switch Firm withdraw from SEC registration?
A The SEC has mandated that Switch Firms must submit an ADV-W for withdrawal from SEC registration no later than June 28, 2012. Do not submit and ADV-W before being approved in Web IARD by the Division.
Q If my Switch Firm is required to register in 4 or more states, is there a way to simplify the registration process?
A If your Switch Firm is required to register in 4 or more state, you may participate in a coordinated review program which is coordinated by the North American Securities Administrators Association, Inc. (NASAA). For more details on this program, please refer to the IA Switch Resource Center on NASAA's website.
Q When must I switch all clients over to a contract applicable to Vermont Law?
A You must have all clients sign an updated contract complying with Vermont law within 120 days of approval in VT.
Q Who can I contact for additional questions?
A You can contact the Division directly at 802-828-3421 or send an email to BISHCA.Securities-Info@state.vt.us.
In order to ensure there is no lapse in the firm's registration, the Division recommends that completed applications be submitted by May 15, 2012.