New York Attorney General Proposes Modernizing Investment Adviser Regime

May 13th | 2020

The New York Department of Law proposed revisions and modernizations to the rules within Title 13 NYCRR Part 11, which would significantly impact investment adviser representatives, firm principals and solicitors. The full text of the proposed language as amended can be found here. Many of the changes are designed to move filings and payments to standardized federal and multi-state systems. New York’s registration procedures will better conform to the federal securities registration regime including investment adviser representative registration through the Central Registration Depository/Investment Adviser Registration Depository. New York based advisers should be aware of record keeping changes requiring investment advisers to maintain records of reasonable steps taken to very “accredited investor” and “qualified purchaser” status. In addition, the proposal redefines and classifies “Finders” and “Solicitors” to explicitly require meeting registration and exam requirements. Further comments from the New York Attorney General can be found here.

There is a 60 day comment period that initiated on April 15, 2020.

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