Wyoming is unique among the 50 states in that no formal registration requirements exist for investment advisers. Federal registration requirements will still need to be met for advisors working in Wyoming managing client assets in excess of $100 million or if conducting business in other states.
The following guide will detail the process for federal registration through the Securities and Exchange Commission (SEC) for investment advisers working in Wyoming or those based in Wyoming but serving clients in other states.
Step 1. Get a Degree
Plan on pursuing a bachelor’s degree. This will assist you in highlighting your skills for potential clients in Wyoming. Once you have completed all degree requirements, the data will be stored in the Investment Adviser Public Disclosure (IAPD) and will be accessible to potential clients.
The degree paths below could take you all the way to a PhD, some to consider are:
- BS-Accounting
- BA-Accounting
- BA-Consumer and Family Financial Services
- MS-Personal Financial Planning
- MS-Finance
- MS-Accounting
- MBA –Finance or MBA-Accounting and Finance
- PhD-Accounting
- PhD-Finance
Courses to either include in your degree curriculum or simply take alone are:
- Economics
- Taxation
- Management
- Accounting
- Finance
- Behavior of groups, persons, and organizations
- Ethics of business
- Business communications
- Business law
- Computer information systems
- Marketing
- Statistics
- Quantitative applications applied to business
It is always wise to embrace the opportunity to enhance your educational skills. The Investment Advising career path is competitive and education can be the key to standing out among the rest. The trick is that you must have at least a bachelor’s degree or real world experience in order to proceed with some of these opportunities. One of the most beneficial ways to embrace these opportunities is to test for a profession designation, these are:
- Certified Financial Planner (CFP)
- Chartered Financial Analyst (CFA)
- Personal Financial Specialist (PFS)
- Chartered Financial Consultant (ChFC)
- Chartered Investment Counselor (CIC)
Step 2: Register Your Firm in Wyoming
(This step is required for those establishing a new IA firm. If your career will begin with an existing firm, skip to Step 3.)
In the event that you or your firm manages more than $100 million in client assets, you will be required to complete all federal-mandated SEC requirements. If you will manage less than that, and will be practicing in Wyoming exclusively, you will not be required to register.
Federal registration is done through the Investment Adviser Registration Depository site.
- Submit the Entitlement Forms. In these forms, you or a representative from your firm are required to assign a Super Accountant Administrator (SAA). The SSA will ensure that all forms are updated throughout the year and will have access to FINRAs Web-based systems and the Firm Gateway, which will allow for the completion of the remaining steps.
- Fund your IARD User Account to pay the following fees:
- Initially, you will pay a $225 filing fee for SEC-registered advisors; this includes firms with greater than $100 million in assets under management
- Test fees for all principals and representatives of the firm
- Complete the Form ADV. This form is utilized to outline the firm’s employee data, fee structures, and investment philosophies and will be accessible to clients and state regulators.
Requirements to Transact Business in Other States
Investment Advisors who are headquartered in Wyoming can conduct business in any other state. This is with the understanding that once a fifth client is managed, the RIA must register in the state they are conducting business in. This also requires the payment of all new state fees.
Step 3: Get Your Registered Investment Adviser License in Wyoming by Taking the Required Exam
The Wyoming Securities Act regulates the securities business in the state, and although you will not have to register or complete testing to be considered an RIA in Wyoming, you should still consider meeting the following requirements so that you can be recognized in other states as you add business. Federal level Securities and Exchange Commission (SEC) registration will still be necessary, even for Wyoming firms, when your firm’s assets under management reach more than $100 million.
To be licensed and able to conduct more than a minimal amount of business in other states, you will be required to complete an exam or obtain a waiver by completing one of the following professional designations:
- Chartered Financial Analyst (CFA)
- Personal Financial Specialist (PFS)
- Chartered Investment Counselor (CIC)
- Certified Financial Planner (CFP)
- Chartered Financial Consultant (ChFC)
- Choose from one of the following exam scenarios:
OR
- Series 7, General Securities Representative Examination and the Series 66, Uniform Combined State Law Examination.
Exam registration for all firm representatives will be completed with the following form:
- Form U-4 Uniform Application for Securities Industry Registration or Transfer. This serves as both the exam application and the federal registration of firm representatives.
- You can find a Prometric or Pearson Professional Center testing location in Wyoming.
- The allotted time for completing a mandatory exam once the registration process has been completed is 120 days.
- You should try to arrive at least one hour early on exam day.
- Test scores are released immediately after completion of the required exam(s).
Step 4: Ongoing Renewal and Update Requirements in Wyoming
Investment Advisor Firm:
- License renewals within the IARD are required by the December 31st deadline each year
- Additional IARD renewal fees are $100
- There are no Wyoming renewal fees
- Form ADV updates should be completed at least once every twelve months
- All renewal fees will need to be paid for each state the IAR is currently registered in
Investment Adviser Representatives:
Form U-4 must be updated for representatives of IA firms. Firm employees will provide their SAA with the information that needs to be updated; while a sole proprietor will update their own forms. Any changes to the following will require an update:
- Residential address
- Criminal record
- Civil judgments
- Name change (marriage)
- Certifications
- Disciplinary action
- Educational background
- Client complaints
- Additional business activities
