If you’re an advisor planning to start an RIA in Montana, this is what you need to know.
If you meet these criteria, then you’ll need to register your Registered Investment Advisor (RIA) with Montana: Your place of business is in the state and you manage less than $100 million of client assets, you solicit your financial services in the state, or are managing assets for more than five clients that are Montana residents.
If you would like to make this registration process easier for yourself, you may consider hiring a compliance consultant.
To operate an RIA in Montana, an advisor must have one of the following professional designations: Series 65, Series 66 or Series 24, CFP, CFA, CIC, ChFC, or PFS.
Advisors must complete and submit the following forms and policies to start an RIA in Montana:
In addition to paying all the registration and filing fees, IARs must complete the following tasks and submissions with the state:
Submit FINRA Entitlement PaperworkTo process your registered investment advisor application in Montana, you must apply for an account on FINRA’s WebCRD/IARD online system. The state of Montana uses FINRA’s system to process applications, but FINRA doesn’t regulate or supervise RIAs.
Form ADV Part 1 (online portion)Form ADV Part 1 is the online piece for the firm’s registration application. Here the advisor will disclose all the information related to the firm, including ownership, business practices, clients, disciplinary events related to the advisor or its employees, and any affiliations. This is also used to upload ADV Part 2A and ADV Part 2B.
Form ADV Part 2A (paper and online)Form ADV Part 2A serves as the RIA’s disclosure brochure. An advisor will share information about the RIA’s fees, services, disciplinary disclosures, and other information related to the firm that clients need to know. It’s required that this brochure is given to prospective and current clients, and it must be easy to read and understand.
Form ADV Part 2B (paper and online)This is another brochure that, in most cases, must be given to clients. This brochure will include details about the advisor, their education, employment history, potential conflicts of interest, and any disciplinary actions. Any Executive Officers or representatives who advise clients must also complete this form.
If sponsoring a wrap fee program, Appendix 1 is also required.
Form U4This form is used to register your firm’s Investment Adviser Representatives (IARs).
The Montana Commissioner of Securities & Insurance (CSI) may require additional information such as:
Client Advisory ContractIn Montana, regulatory standards for client advisory contracts must be met. This filing will ensure that the RIA meets those required standards.
Policies and Procedures ManualThe Policies and Procedures Manual is an internal document that RIA’s will use to uphold processes and procedures. This manual will include information from how the RIA handles client complaints to how it trains new IARs. It must also have information on Anti-Insider Trading plans, Business Continuity, Anti-Money Laundering, and Information Security.
Code of EthicsThe state sets forth specific fiduciary standards. Filing the Code of Ethics will ensure these are met.
Starting an RIA doesn’t have to be overwhelming with the right resources, such as our comprehensive RIA launch kit.
At Altruist, we strive to make independent financial advice better, more accessible, and more affordable. Our platform gives back precious time and capital to RIAs, so you can focus on what matters most: your clients and business.
On one intuitive, integrated platform, advisors can open and fund accounts, trade and rebalance, report, and bill, at a fraction of today’s edging-ever-higher technology costs.
Our dedicated customer support team is here to help advisors that are planning to make the leap from their wirehouse. Our team will help ensure a smooth transition with exceptional ongoing service.
To see how we’re helping RIAs streamline operations, reduce overhead, and elevate the client experience, book a call with one of our transitional specialists now.
*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.