Tuesday, November 4, 2014

Client Geography Review

As we prepare for annual renewal season, we strongly suggest that you run a client geography report to determine if you have clients outside your home state that exceed the de minimis threshold for that state.

Most states have set the de minimis threshold at 5 clients, meaning, if you do not have a place of business in that state, you may have up to 5 clients before you need to register or notice file. The are four (4) states that are exception, including:

  • Louisiana
  • Texas
  • Nebraska
  • New Hampshire

These states generally require firms to notice file (SEC) or register (state) prior to doing any business. Investment Advisor Representatives may also be required to register.

AdvisorAssist will analyze your geography report and determine which states you are required to be registered based on the report and the nuances of the various state regulations. You can submit these reports from your Advisor Portal under Compliance Activities > Submit Support Request.

It is best to complete these reports prior to November 10, 2014, as Preliminary Renewal Statements are released by FINRA on that date.

If you have any questions, please contact your AdvisorAssist consultant or email us at support@advisorassist.com.

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