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Broker Dealer Guide

Investment Advisory Services

If the broker-dealer intends to provide investment advisory services for compensation as part of its regular business but not through a subsidiary or affiliated company, it must file for a separate registration or notice filing depending on whether the firm is a federal covered investment adviser or a state registered investment adviser.

For federal covered advisers making their first notice filing, the broker-dealer must make a notice filing on IARD and amend its Form BD application “Types of Business.” The fee for a notice filing is $200. There is no review of the notice filing other than for branch office information.

Any agent of the broker-dealer who intends to provide investment advisory services for the broker-dealer/investment adviser must be registered as an investment adviser representative of the federal covered adviser. A person who will only provide advisory services and not sell products to customers is permitted to only register as an investment adviser representative for the federal covered adviser but not as an agent of the broker-dealer. See the Investment Adviser Guide for investment adviser representative qualifications.

If the broker-dealer will also conduct activity as a state registered adviser, the broker-dealer must file an application for registration as an investment adviser via the IARD and file an amendment to its Form BD application “Types of Business.” The fee for initial registration as a state adviser is $400. Any agent of the broker-dealer who intends to provide investment advisory services for the investment adviser must be registered as an investment adviser representative of the state registered adviser. A person who will only provide advisory services and not sell products to customers is permitted to only register as an investment adviser representative for the state registered adviser but not as an agent of the broker-dealer. See the Investment Adviser Guide for investment adviser representative qualifications.

Broker-dealers offering investment advisory services as state registered advisers must comply with investment adviser record keeping and other requirements inasmuch as the investment adviser is a separately registered entity. Please review the Investment Adviser Guide for more information.