Michigan Investment Advisor Registration Process
Last updated: August 27, 2024
How to Register as an Investment Advisor in Michigan
FINRA Entitlement Paperwork: To initiate the process of becoming a registered investment advisor in Michigan, individuals must first apply to the Financial Industry Regulatory Authority (FINRA) to create an account (Entitlement) for their WebCRD/IARD online system (the web application for the registration of RIA and its representatives). FINRA does not regulate or supervise RIAs, but the State of Michigan uses FINRA’s WebCRD/IARD system to process applications.
Form ADV Part 1: Electronically file Form ADV through IARD. Form ADV Part 1 discloses information about the RIA, including its ownership structure, client base, operational practices, any disciplinary incidents involving the advisor or their employees, and affiliations. This form acts as the online portal for submitting additional documentation within the system.
Form ADV Part 2A: Detail your RIA’s fee structure, services, disciplinary disclosures, and other firm information in Form ADV Part 2A. Form ADV Part 2A is also known as the Firm’s Disclosure Brochure.
Form ADV Part 2B: Form ADV Part 2B provides information about the advisor, such as their education, employment history, potential conflicts of interest, and any disciplinary actions.
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Minimum Net Capital for most advisers: According to State Code, "(2) An investment adviser registered, or required to be registered, under the act who has custody of client funds or securities shall maintain at all times a minimum net worth of $35,000.00 except for the following circumstances: (a) An investment adviser having custody solely due to direct fee deduction and complying with the terms described under R 451.4.13 and related books and records, as described in R 451.4.24, is not required to comply with the net worth or bonding requirements of this rule. (b) An investment adviser having custody solely due to advising pooled investment vehicles and complying with the terms described under R 451.4.13 and related books and records, as described in R 451.4.24 is not required to comply with the net worth or bonding requirements of this rule. (3) An investment adviser, registered or required to be registered, under the act who has discretionary authority over client funds or securities but does not have custody of client funds or securities shall maintain at all times a minimum net worth of $10,000.00. (b) Every investment adviser registered or required to be registered under the act who has custody or discretion of client funds or securities who does not meet the minimum net worth standard in R 451.4.17 shall be bonded in the amount of the net worth deficiency rounded up to the nearest $5,000.00." Source, Source 2
Surety Bonds: Required if advisor falls below minimum net capital requirement and has discretionary authority
Fees: Submit a $200 fee for the firm's registration through FINRA IARD.
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