Description of Services
FINRA Entitlement Paperwork:
In order to file a registered investment adviser application with the appropriate regulatory jurisdiction, one must first apply to the Financial Industry Regulatory Authority (FINRA) for an account (Entitlement) to their WebCRD/IARD on-line system (the web application for the registration of RIA’s and their representatives). While RIA’s are in no way regulated or supervised by FINRA, the states and the SEC use FINRA’s WebCRD/IARD system to process applications.
RIA In a Box will complete the appropriate Entitlement forms, submit, monitor, and establish the appropriate user permissions (Entitlements) to the account.
ADV Part 1:
The Form ADV Part 1 is the on-line component to your Firm’s registration documentation. Note: The Form ADV Part 1 primarily discloses information about the FIRM. Individual information is primarily disclosed in the Form U4 as detailed below.) The Form ADV Part 1 is also the vehicle to upload your Firm’s Form ADV Part 2A (Firm Brochure) and Form ADV Part 2B’s (Brochure Supplements).
RIA In a Box will complete the on-line Form ADV Part 1 and accompanying Schedules: A (Ownership Information); B (Indirect Ownership Information); D (Detail Information for Form ADV Part 1 disclosures including: Private Fund, Branch Office, and Affiliation Information disclosures); Form ADV Part 1B (Additional Required Information for State Registered Advisers); and RIA In a Box will also upload the Form ADV Part 2A and the Form ADV Part 2B’s to the Form ADV Part 1.
Form ADV Part 2A:
The Form ADV Part 2A acts as your Firm’s Brochure. It is a narrative description of your services, fees, disciplinary disclosures, as well as several other Firm details. The Form ADV Part 2A must be provided to all Clients and Prospective Clients. All jurisdictions require that the ADV Form 2A be written in “plain English” and easily understood by your clients.
After a thorough information gathering/interview process, RIA In a Box will create an Form ADV Part 2A built specifically to your Firm’s business model while ensuring that its format, content, and disclosures meet your jurisdiction’s compliance requirements. Because the RIA must provide the Form ADV Part 2A all clients and prospective clients, RIA In a Box ensures the document is attractive, compliant, and accurate. RIA In a Box will brand your form ADV Part 2A Brochure with your firm’s logo.
Form U4:
The Form U4 is the on-line component for an individual’s registration to a Registered Investment Advisory Firm. The form U4 is filed with the appropriate jurisdiction(s) in which the Investment Adviser Representative will be working using FINRA’s WebCRD system. The form must be accurate and includes biographical, residential, employment, outside business activity and disciplinary history. The information from this form is used to populate the publically available information on the Investment Adviser search site maintained by the SEC.
Client Advisory Contract:
RIA In a Box will help you create your firm’s standard Client Advisory Contract including an investment policy statement ensuring you meet the appropriate regulatory authority standards for client advisory contracts.
Form ADV 2B (Brochure Supplement):
The Form ADV 2B is the paper brochure that Investment Adviser Representatives must (in most cases) provide to clients. This form contains employment, educational, conflict of interest, and disciplinary information. Generally, Executive Officers, any person generating investment advice provided to clients, and any representative advising clients must have a Form ADV Part 2B.
Privacy Policy Statements:
The Firm’s Privacy Policy Statement must be provided to all clients at the beginning of the client relationship and annually thereafter. It must disclose how the firm stores, and handles and disseminates client information. RIA In a Box’s Privacy Policy Statement are built to your firm’s specifications and designed to meet regulatory authority compliance requirements.
Chief Compliance Officer Training:
Our Chief Compliance Training is a comprehensive manual that guides your firm’s Chief Compliance Officer (CCO) through your firm’s disclosure and compliance documents ensuring that the firm’s compliance is satisfied on day one.
Code of Ethics:
RIA In a Box will help you craft your firm’s Code of Ethics ensuring you meet the appropriate regulatory authority standards and are set up to conduct your business with the proper ethical standards.
Business Continuity Plan (BCP):
RIA In a Box will help you craft your firm’s Business Continuity Plan ensuring you meet the appropriate regulatory authority standards and are properly prepared should the unexpected business disruption occur.
Policies and Procedures / Compliance Manual:
The firm’s Policies and Procedures manual is the guiding document that your firm will use to maintain and enforce your firm’s internal policies on all aspects of your business from the handling of client complaints to the training of new Investment Adviser Representatives. It also houses your firm’s Business Continuity Plan, Privacy Policy, Anti-money Laundering Policy, Anti-insider Trading Policy, etc.
RIA In a Box will work with you to create a robust manual that is also a usable tool written in plain English and easily navigable. This is a very comprehensive, tailored document that will be the foundation of conducting advisory business in a compliant manner.
Adding Additional States:
While the description of your firm’s services and fees should remain constant across the jurisdictions (states) in which the firm is applying, different jurisdictions can have vastly different disclosure requirements. RIA In a Box will guide you through this process, creating and amending documents so that they are in compliance across all state jurisdictions.
A registered investment adviser must generally register in any state in which it has a physical location, a representative physically located, has 5 or more clients (or just 1 client in regards to Texas and Louisiana), or has “boots on the ground” soliciting in the state. A handful of states require registration even if an RIA is only soliciting in the state remotely.
Adding Additional Representatives:
All representatives of your firm need to be registered to the RIA if they are providing or generating advice. In general all executive officers or people who have Control of the RIA should also be registered to the firm. Registration includes filing a U4, ensuring the testing requirements or testing exemptions are satisfied, creating an Form ADV Part 2B brochure supplement and, in most cases, uploading that the ADV Form Part 2B to FINRA’s WebCRD system.
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