Advisors planning to start an RIA in Missouri must familiarize themselves with the state requirements. This article will explore what those are so advisors can better prepare.
Who is required to register in the state of Missouri? If an advisor lives in the state, solicits their services, or serves Missouri residents, they must register their RIA with the state.
If it seems overwhelming to do this on your own, consider hiring a compliance consultant to help make this process easier.
Financial statement requirements for the state of Missouri:
Advisors must have one of the following professional designations to operate in the state: Series 65, Series 66 and Series 7, CFP, CFA, CIC, ChFC, or PFS.
For Individual Advisor Representatives (IARs) to register their RIAs, they must pay all the filing fees and complete the following tasks and submissions with the state:
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Submit FINRA Entitlement Paperwork
It should be noted that FINRA doesn’t supervise or regulate RIAs, but the state uses its system to process registered investment advisor applications. As such, it is required that IARs apply for access to FINRA’s Web CRD/IARD online system to complete their registration process. -
Form ADV Part 1 (online portion)
This is the online component of the ADV, and Form ADV Part 1 is all about the RIA only. Within this, an advisor will disclose information about ownership, clients, business practices, and any disciplinary events related to the firm, the advisor, or its employees. It should also list any affiliations.
Form ADV Part 1 is also used to upload ADV Part 2A and ADV Part 2B. -
Form ADV Part 2A (paper and online)
Otherwise known as the Firm’s Disclosure Brochure. In Form ADV Part 2A, an advisor will include information about fees, services, disciplinary disclosures, and other details related to the firm. It’s required that this brochure be given to prospective and current clients; therefore, it must be written in easily understandable English (the state of Missouri also requires this).
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Form ADV Part 2B (paper and online)
This is another brochure that's often given to clients. In Form ADV Part 2B, an advisor will share details about their education, employment, potential conflicts of interest, and any disciplinary actions.
Additionally, any Executive Officers or representatives who advise clients must complete this form. -
Client Advisory Contract
This filing ensures that the RIA follows Missouri's regulatory authority standards for client advisory contracts. - Code of Ethics
The Code of Ethics submission lets the state know that the RIA aligns with the fiduciary standards required by Missouri. -
Privacy Policy Statement
This statement must include information about how the RIA handles, stores, and shares client information. This statement must be given to clients at the start of the working relationship and annually thereafter.
While this statement will be unique to the RIA, it still must meet the state’s compliance requirements. -
Policies and Procedures Manual
This internal manual will contain information about how the RIA will maintain and enforce its internal policies. Within this manual, there must be details from how the RIA handles client complaints to how it trains new IRAs. It must also include information on Anti-Insider Trading plans, Business Continuity, Anti-Money Laundering, and Information Security.
Starting an RIA doesn’t have to be overwhelming with the right resources, such as our comprehensive RIA launch kit.
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*Altruist and its affiliates do not provide legal advice, so it’s important to check with a qualified professional for each state’s registration requirements.