If you’re a robo-adviser, chances are you want to create a fully “digital” experience for clients that doesn’t involve sending paper documents. For example, you may want to email clients or communicate with them directly through your firm’s online platform. If you’re going to ditch the paper, the SEC expects you to follow its guidance
Even though your firm may be registered with the SEC, a state can impose licensing requirements on individuals associated with your firm who (i) have a “place of business” within the state and (ii) fall within the state’s definition of “investment adviser representative” (or “IA Rep”). These requirements should be met before any individuals begin
Before your robo-adviser can accept its first client, it must be registered. Like other investment advisers, robo-advisers have two possible initial registration pathways. They either register with the SEC or they register with the state(s) where they maintain a place of business. Due to the additional complexity associated with state registration, most robo-advisers seek to
Thanks for taking the time to check out our first of many blog posts designed to help robo-advisers operate more efficiently, reduce business risk, and comply with applicable law.
To start, when we say “robo-advisers” or “you,” we mean registered investment advisers that use technology to provide discretionary asset management services to their clients through