Financial advisor is a general term used to describe licensed and registered investment adviser representatives (IARs) or sole proprietors of investment adviser (IA) firms. This step-by-step guide on how to become a financial advisor and establish an investment adviser firm (IA) in Missouri covers the state level registration process with the Missouri Securities Division and the federal level registration process with the Securities & Exchange Commission (SEC).
Step 1. Get Your Education
- Pursue a degree program structured to help you become an investment adviser. It’s not uncommon to see advisers with highly specialized degrees since information on their educational background is available to clients and regulators through the Investment Adviser Public Disclosure (IAPD) database. In most cases, individuals who provide investment advisory services hold a bachelor’s or master’s degree in related areas of study:
- BA-Consumer and Family Financial Services
- BA or BS -Accounting
- MBA-Accounting and Finance or simply Finance
- MS-Accounting, Personal Financial Planning, or Finance
- PhD-Accounting or Finance
- Ethics in business
- Management
- Statistics
- Marketing
- Finance
- Accounting
- Business communications
- Computer information systems
- Behavior of groups, persons, and organizations
- Economics
- Taxation
- Business law
- Quantitative applications applied to business
- Chartered Investment Counselor (CIC)
- Personal Financial Specialist (PFS)
- Certified Financial Planner (CFP)
- Chartered Financial Consultant (ChFC)
- Chartered Financial Analyst (CFA)
Step 2: Register Your Firm in Missouri
(This step is only applicable if you plan to establish your own IA firm. If you will start your career by working with an established firm, you can skip to Step 3.)
To operate an independent practice in Missouri, you’ll need to complete the investment advisor (IA) registration process through the FINRA administered Investment Adviser Registration Depository (IARD). This process registers your new firm with the Missouri Securities Division if it will be managing more than $100 million in client assets. Follow this same process to register the firm with the SEC if managing client assets in excess of $100 million.
- Begin the FINRA Entitlement Process by opening an IARD User Account and completing the Entitlement Forms specific to the New Investment Adviser Firm (Section 3). This process allows you to gain access to FINRA’s Web-based systems. Your new firm is required to designate a Super Accountant Administrator (SAA) who will have access to the FINRA Firm Gateway and have the ability to complete the remaining steps.
- All required state filing fees, registration fees, IAR registration and testing fees are funded through your IARD User Account, a list of the fees are as follows:
- $200 initial state firm filing fee that is charged by the Missouri Securities Division
- Initial IARD set up fees for state registered investment advisors are currently being waived
- $50 initial state IAR filing fee that is charged by the Missouri Securities Division for each IAR that will be employed by the firm
- $225 initial filing fee for SEC-registered advisors, which include firms with over $100 million in assets under management
- Exam fees for each IAR that will work for the firm
- A notarized copy of the State Covered Investment Adviser Affidavit
- A sample of any written agreements that will be used with clients
Requirements to Transact Business in Other States
Now that your firm is registered in Missouri, a small amount of business transactions can take place with out of state residents without needing to meet further registration requirements. Under most circumstances, this means that your firm cannot have more than four out of state clients in any one state. When a fifth client is added in any one state, you must use the IARD system to register in that state and pay all required fees.
Under the De Minimis Exemption, out of state RIA’s are allowed to work with as many as five Missouri resident clients; however, they are still required to register when a sixth Missouri client is added.
Step 3: Get Your Registered Investment Adviser License in Missouri by Taking the Required Exam
If your new firm will offer most of its services to Missouri-based client and work with less than $100 million in managed assets it will operate under the Missouri securities statutes. IA firms managing assets over $100 million are regulated by the Securities and Exchange Commission (SEC). Exam requirements are waived by the SEC and on a case-by-case basis by the state of Missouri for would-be IARs who have completed at least one of the professional designations listed below:
- Chartered Financial Analyst (CFA)
- Personal Financial Specialist (PFS)
- Chartered Financial Consultant (ChFC)
- Chartered Investment Counselor (CIC)
- Certified Financial Planner (CFP)
- Register for the required exams. Missouri requires that IAR candidates complete one of the following:
OR
- The Series 7, General Securities Representative Examination, which will require sponsorship through a FINRA-member firm, in combination with the Series 66, Uniform Combined State Law Examination
Register using one of the following forms:
- The Form U-4 Uniform Application for Securities Industry Registration or Transfer, can be prepared and submitted through the IARD. Form U-4 serves as both the registration application and as the IAR’s exam application.
OR
- Form U-10, the Uniform Examination request for non-FINRA Members, is an exam-only application for non-sponsored exams and will not complete the IAR registration process. The U-10 cannot be used to apply for the Series 7 exam, since it requires a sponsor. When using Form U-10 to apply for the Series 65 Exam, you still need to formally register within two years of passing the exam using Form U-4.
Step 4: Ongoing Renewal and Update Requirements in Missouri
Investment Advisor Firm:
- Annual updates to the ADV will always be required
- License renewal actions must be completed by December 31st every year
- IAR license and IA firm renewals will be completed through the IARD
- Missouri’s renewal fees are $100 for the firm and $50 for each IAR within the firm
- Additional IARD renewal fees are $100
- Renewal fees are paid for all states in which the firm’s IARs are registered
Investment Adviser Representatives:
IARs should maintain and update their own Form U-4. Anyone operating as a sole proprietor should make required updates themselves. When employed by a firm, the firm’s compliance department and SAA should be notified and make necessary updates within 30 days of status changes to any of the following:
- Certification
- Additional business activities
- Disciplinary action
- Name change (marriage)
- Education
- Residential address
- Customer complaints
- Civil judgments
- Jurisdictional changes
- Criminal record
