Vermont Investment Advisor Registration Process
Last updated: August 27, 2024
How to Register as an Investment Advisor in Vermont
FINRA Entitlement Paperwork: To initiate the process of becoming a registered investment advisor in Vermont, 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 Vermont 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, "(a) an investment adviser having custody as described in Item 9(a) of these instructions must either meet a $35,000 minimum net worth requirement or post a bond in the amount of the net worth deficiency, rounded up to the nearest $5,000. * (b) an investment adviser having discretion as described in Item 9(b) of these instructions must meet a $10,000 minimum net worth requirement or post a bond in the amount of the net worth deficiency, rounded up to the nearest $5,000.* Vermont's balance sheet, net worth and bonding requirements are not applicable to an investment adviser registered or licensed in a state where it maintains its principal place of business AND is in compliance with such state's requirements." Source
Surety Bonds: Permitted in lieu of Net Capital; only required if advisor has discretionary authority
Fees: Submit a $300 fee for the firm's registration through FINRA IARD.
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