November 29, 2010
A new class of advisor has been identified as mid-size advisors. These are advisors currently registered with the SEC who will be transitioning to registration with the states in which they do business. They have between $30 and $100 million AUM.
The estimated total number of this class of advisor is 4100.
While making these changes, would it be possible to include one further change?
Each advisor will be required to register with the state which is their principal place of business. Currently, these advisors use the IARD system to notice file with all other states in which they do business. This system is in use for all states and jursidictions and is efficient, cost-effective, and timely for both the states and the advisors. If the mid-size adviosors could continue to use the notice filing system for those states in which they do business other than their home state, it would greatly reduce the regulatory burden on both the advisors and the states.
Thank you for your consideration.