Registration, Regulatory Filings, and Ongoing Support

Registration Services

For many the registration process your Registered Investment Advisor (RIA) or Broker-Dealer can be overwhelming and burdensome. To successfully navigate the process takes time, extensive industry knowledge, and a keen eye for detail. This is why Bates takes a holistic approach to the registration process by working with you from the initial idea all the way to the final approval. We ensure that your firm is set not only to pass initial review from SEC, FINRA or State, but also has a well-designed compliance program tailored to your specific operation.

Bates will take into consideration several factors such as your firm’s business model, compensation structure, expected assets under management, investment offerings, and even the location of the firm and its clients. It is critical that your firm operate with the appropriate registration as your applicable regulator will expect that, upon approval, you meet all the regulatory requirements from that point forward.

Bates provides registration services for the following:

Registered Investment Advisors (SEC or State)
Broker-Dealer – New Member Application (NMA)
Exempt Reporting Advisers (ERA)
- Generally, this applies to firms that advise private funds only, with assets under $150 million.
Transition Filings (State to SEC or SEC to State)
- Generally, this applies to RIAs when they exceed or fall below $100 million in AUM.

Registered Investment Advisors (SEC or State)

Registered Investment Advisors will receive a host of various services and documents that include, but are not limited to:

FINRA SAA/IARD Setup
ADV Part 1A
ADV Part 2A and 2B(s), Wrap Appendix
Form CRS
Form U4(s)
Compliance Manual & Code of Ethics
Business Continuity Plan
Privacy Notice
Compliance Calendar
Sample Client Agreement(s)
Other required documents as needed

In addition, the client will be able to leverage the knowledge of the Bate’s consultant to explain the content and implementation of all required documents.

Broker-Dealers

Broker-Dealers will receive a host of various services and documents that include, but are not limited to:

Name reservation with FINRA
FINRA SAA Setup
Form NMA
Form BD
Form U4(s)
Written Supervisory Procedures (WSP)
Anti-Money Laundering Program (AML)
Written Continuing Education Plan
Pro forma financials and business plan
Organization and Supervisory Charts
Evaluation of vendors for recordkeeping purposes such as email
Business Continuity Plan
Membership Interview Preparation

Regulatory Filing Services

Bates provides the following registration services:

Annual Updating Amendments (AUA)
EDGAR Filings (Forms 13D, 13F, 13H, 3H, & N-PX)
SEC Filings (Forms U5, U5, BR, PF)
Regulation D and Initial Form D Filing
Blue Sky Filings

Ongoing Support Services

Rule 206(4)-7 (Annual Review)

Bates will conduct an SEC required Annual Review that will focus on assessing the adequacy and effectiveness of your compliance program to fulfill the requirements under Rule 206(4)-7 of the Investment Advisers Act of 1940. Bates will prepare a written report that details the policies reviewed, our observations, and any recommendations for improvement.

FINRA Rule 3120/3130 Report

Bates will conduct a FINRA required Annual Review, pursuant to FINRA Rules to test your system of supervisory procedures and internal controls. This is a review to ensure the adequacy and effectiveness of the compliance controls and to provide a summary of the test results and significant identified exceptions. The review will also consider rule changes, as well as recent regulatory developments.

Ad Hoc Services & General Consulting

Bates may be engaged for more general consulting or as-needed projects such as: