Montana Requirements for Starting an RIA
If you’re looking to register a new RIA in Montana , our experienced Brighton based team and broad Network of industry leading partners are here to help you achieve your goals and anticipate Montana ’s developed State regulatory guidelines all-while enabling you to continue focusing on what you do best.
We are driven to help fellow Montana based advisors by providing them true simplicity. This is why we ensure we thoroughly understand your business today and goals for tomorrow before beginning our work. This foundation of understanding is the base upon which our “we-do-the-heavy-lifting-for-you” service style stands and best ensures our completely custom work to have no gap between your intent and our implementation.
Montana RIA Registration
To register an RIA in Montana in 2016 you will need to submit the documents listed below and pay an initial firm filing fee to Montana’s Securities Division of $200.
Required For Approval
These will be required whether you’re filing a new RIA for the first time or expanding an existing firm into Montana:
- Form ADV Part 1
- Form ADV Part 2A
- Form ADV Part 2B (atleast 1 IAR)
- Form U4 (atleast 1 IAR)
- Wrap-Fee Brochure (if applicable)
- Client Agreement(s)
- Corporate Documents, Filings & Financials
- Net Capital Requirements of $10,000 if Servicing Discretionary AUM
- GAAP Balance Sheet & Income Statement
New RIA Also Required
You will also need to complete the following items if you are seeking approval as a state RIA for the first time:
- SAA Creation & FINRA Entitlement
- IARD/CRD Access & Authentication
- E-billing establishment & processing
Beyond RIA Registration
These documents and processes form a living set of procedures which guide your RIA and each employee away from potential problems and towards the required Montana compliance standards. These documents essentially ensure your firm’s adherence to applicable regulations, and aren’t going to be reviewed or approved by your regulators during the application process. Your RIA will however still be expected to develop, maintain and adhere to adequate standards including:
- Policies & Procedures Manual
- Code of Ethics
- Cyber Security Policy
- Business Continuity Plan
- Compliance Procedures, Monitoring, & Execution
If you’re interested in learning more about what’s involved in successfully filing a new Montana RIA or need to register an existing RIA in Montana to comport with De Minimis rules you can reach us by phone at 810-227-2549 or simply submit our contact us form. You can learn more about our turn-key New State RIA Registration services here or learn more about our additional State filing services here.
Montana Annual RIA Renewals
In 2016, each Montana RIA will pay $200 in state firm annual renewal fees via FINRA’s IARD system. Within 90 days of the new year each Montana RIA will also have to file its annual amendments, indicating material changes and certifying a complete disclosure provenance, in addition to executing the renewal process for each of the firm’s IARs.
Whether you are looking for a cost-effective solution for your annual compliance requirements which can scale to meet your needs on-demand or you need to bring on a comprehensive compliance program and officer, we have the experience, know-how, attitude, people and resources to protect your firm in an evolving regulatory climate.
Becoming an IAR licensed in Montana will require you to meet the licensing requirements or waivers detailed below and payment of an initial registration fee of $50. Once licensed, Montana IARs will have to be registered with an approved RIA firm within 2 years to maintain their license – this involves updating the Advisor’s form U4 and creation of a Form ADV part 2B brochure supplement. Registration with an approved investment advisor firm is also required before the IAR can conduct any investment advisory business.
In order to be licensed as an IAR in Montana an individual must meet and/or maintain one or more of the following criteria:
- Series 65 License
- Series 7 & 66 Licenses
- CFP Designation
- CFA Designation
- CFA Designation
- ChFC Designation
- CIC Designation
- PFS Designation
If you are interested in becoming a Series 65 Licensed IAR in Montana or are looking for a turn-key solution to process your inbound IAR’s U4s and creation of ADV Part 2B Brochure Supplements contact us today by calling 810-227-2549 or submit our contact us form.
Each year an IAR must have successfully completed the requirements of their firm’s compliance program, certify and acknowledge the firm’s policies & procedures, and ensure the ongoing accuracy of their Form U4 and ADV Part 2B Brochure Supplement. They must also pay their annual renewal fees for continued registration in Montana which are $50 in 2016.
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