General

Investment Adviser

An investment adviser is a person or firm that provides advice about securities for compensation, regulated by the SEC (if managing $100M+) or state regulators, and held to a fiduciary standard.

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Exam Tip

IA = fiduciary standard. $100M+ = SEC registration. Form ADV = disclosure document.

What is an Investment Adviser?

An investment adviser (IA) is any person or firm that, for compensation, engages in the business of advising others about the value of securities or the advisability of investing in securities.

Three-Prong Test

To be classified as an investment adviser, all three must apply:

ElementRequirement
AdviceProvides advice about securities
BusinessIn the business of giving advice
CompensationReceives compensation for advice

Registration Requirements

Assets Under ManagementRegister With
$100 million+SEC
$25-100 millionState (unless eligible for SEC)
Under $25 millionState

Fiduciary Duty

Investment advisers owe clients a fiduciary duty:

  • Act in client's best interest
  • Full disclosure of conflicts
  • Loyalty - put client first
  • Care - provide suitable advice

Key Regulations

RegulationPurpose
Investment Advisers Act of 1940Federal regulation of IAs
Form ADVRegistration and disclosure document
Form ADV Part 2Client brochure with fees, conflicts

IA vs. Broker-Dealer

FactorInvestment AdviserBroker-Dealer
StandardFiduciarySuitability/Reg BI
CompensationFees (usually AUM-based)Commissions
RelationshipOngoingTransactional
RegistrationSEC or StateSEC and FINRA

Investment Adviser Representative (IAR)

Individuals who give advice on behalf of an IA must register as IARs with the state(s) where they have clients.

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