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COMMENT LETTERS - REGULATORY COMPLIANCE INFORMATION

IA Update - Changes to NY State IAR Registrations Coming in 2021 (12/10/20)

NEW YORK STATE IAR REGISTRATIONS TO MOVE TO THE WEB CRD/IARD SYSTEM IN 2021

Good afternoon! I hope this finds you doing well and staying safe!

New York State (NYS) has recently updated their requirement for registering Investment Adviser Representatives (IARs) in the state. As you may have been aware, NYS did not recognize this registration in the past.

Here is a brief summary on the types of changes coming in 2021. Additionally, I’ve attached the full article below for your reference:

CHANGES. The changes require the registration of investment adviser representatives ("IAR") including principals, supervisors and solicitors through the WebCRD/IARD system beginning February 1, 2021.

Prior to the rule change, New York was the only state that did not license investment adviser representatives via the WebCRD/IARD system.

INITIAL REGISTRATION. An IAR for an SEC registered investment adviser will file the Form U4 and pay a $200 fee if the IAR conducts advisory activities from a place of business in New York.

ONGOING REGISTRATION. After initial registration, IARs must renew their registration annually, and make timely updating amendments through the year whenever material changes occur.

EXAM REQUIREMENTS. IARs must pass the Series 65 or the Series 7 and Series 66 within 2 years of registering in NY unless the IAR qualifies for a waiver.

Waivers will be available to IARs for prior registrations -

• have been continuously registered to provide investment advice in any jurisdiction for a period of at least two years prior to the date of filing the Form U4,

• have not had any lapse in registration exceeding two years, and

• are not, and have not been, subject to any regulatory or civil action, proceeding or arbitration, either pending or in the preceding ten years from the date of their application, that would require disclosure on Form U4.

Waivers will be available to IARs for professional designations -

• Certified Financial Planner (CFP)

• Chartered Financial Consultant (ChFC)

• Personal Financial Specialist (PFS)

• Chartered Financial Analyst (CFA)

• Chartered Investment Counselor (CIC)

https://ag.ny.gov/press-release/2020/attorney-general-james-announces-final-rules-modernize-and-stream line-securities

If you have any questions regarding this recent change and how it applies to you and your team, please contact Cathy Cucharale (the source of this update that I am passing on to you) at ccucharale@cucharalegroup.com. Thanks, Cathy!

I hope this update proves helpful and remember to give me a call before you BDW or sell at a discounted rate -- I've been able to help so many small firms get fair market value for their firms. Oh, the stories I could tell you.

(I just don't want anyone to get "picked off" or to BDW when your BD has value. I've actually been amazed by how many people I've been able to help and I'm so happy to do so! We small firms have to look out for one another!)

Wishing you and your family a wonderful holiday season!

Best and warmest regards,

Paige

Paige W. Pierce

(801) 949-5577

paige@paige-pierce.com

Paige Pierce