All you mid-sized advisors switching from SEC to state registration may want to begin preparing for an examination. According to Joe Brady, General Counsel, NASAA, speaking at the recent NRS Conference, states will begin to focus on these advisers since they will be the bigger firms in their states. Many may not have been examined in some time and the states have an interest in making sure that these firms are compliant with state regulations.
So although you may have made the switch and had some of your documents reviewed by state regulators during the registration process, you may want to review your other documents as well. Be proactive – take a look at the state’s document request list and be sure that your documents are consistent with the state’s regulations.
I can tell you this is happening – one advisor had an examination letter arrive less than 45 days after the approval of the advisor’s state registration.