Investment Advisor Services

If the broker-dealer intends to provide investment advisory services for compensation through its broker-dealer registration, there are different requirements depending on whether the firm is a federal covered investment adviser or a state licensed investment adviser.

For federal covered advisers making their first notice filing, the broker-dealer must file an amendment to its Form BD application. The broker-dealer must also notice file in the State of Wisconsin through the IARD system. There will be no filing fees or renewal fees deducted from your CRD account as long as the investment adviser is not a separate entity. The investment adviser activity will be part of the broker-dealer license. Any agent of the broker-dealer who intends to provide investment advisory services for the broker-dealer must be licensed as a securities agent of the broker-dealer, or as an investment adviser representative, but not both. It is the broker-dealer's responsibility to verify that the individual is qualified to offer investment advisory services in Wisconsin through the broker-dealer. See the Investment Adviser Guide for investment adviser representative qualifications.

If the broker-dealer is a state licensed adviser, the broker-dealer must file an amendment to it's Form BD application. The broker-dealer must also apply for approval in the State of Wisconsin through the IARD system. There will be no filing fees or renewal fees deducted from your CRD account as long as the investment adviser is not a separate entity. The investment adviser activity will be a part of the broker-dealer license. Any agent of the broker-dealer who intends to provide investment advisory services for the broker-dealer in Wisconsin must be licensed as a securities agent of the broker-dealer, or as an investment adviser representative, but not both. It is the broker-dealer's responsibility to verify that the individual is qualified to offer investment advisory services in Wisconsin through the broker-dealer. See the Investment Adviser Guide for investment adviser representative qualifications.

When filing an application for an agent on CRD, no filing for the RA category should be made for any person who will be licensed as an agent for the broker-dealer and has passed the exams necessary to provide advisory services. Any such RA filing will result in the RA status being changed to T_NOU5 to terminate the status as filed in error.

If however, the applicant will only provide advisory services and will not be licensed as a securities agent to offer and sell securities products, a filing as an RA will be appropriate. The firm may wish to enter a notation under Registration Comments on the person's CRD record to indicate that person will be acting in an advisory capacity only and will not offer and sell securities.

Broker-dealers offering investment advisory services must also comply with investment adviser record keeping requirements which can be found in the Investment Adviser Guide.