Starting an RIA is exciting, but it's important to know the different requirements for each state. This article will look at the specific requirements for the state of Tennessee.
Who is required to register as an RIA in Tennessee?
Generally, Advisors in Tennessee with fewer than 100 million in AUM, have 5 or more clients, or actively soliciting their services must register as an RIA.
You might consider registering with the SEC if you’re managing over $100 million in AUM.
Hiring a compliance consultant can make navigating this process easier, but if not, this article can provide the necessary guidance..
Financial statement requirements for RIAs in Tennessee:
Tennessee requires a balance sheet from every RIA. Also, RIAs with custody have to submit audited financial statements.
In Tennessee, 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.
Also, every advisor has to submit the form U-4 and ADV part 2B.
Policy and Form requirements for starting an RIA in Tennessee:
Filing with Finra
In addition to paying all the state’s registration filing fees, advisors must complete the following:
- Apply for an account to FINRA’s WebCRD/IARD
Finra does not regulate or supervise RIAs, but the state uses the system to process applications. Therefore advisors must apply for an account to FINRA’s WebCRD/IARD online system.
- Form ADV Part 1 (online portion)
This section of the ADV pertains to information about the RIA only. Personal details are provided in Form U4 and ADV Part 2B. This form is the online component of the registration process. It’s also used for uploading ADV Part 2A and ADV Part 2B.
- Form ADV Part 2A (paper and online)
This brochure provides important information about your RIA, such as fees, services, disciplinary disclosures, and other details. It should be provided to all prospective and current clients. Tennessee requires this to be written in clear and easily understandable language.
- Form ADV Part 2B (paper and online)
Form ADV 2B is a brochure IARs must typically give clients. It includes information on education, employment, potential conflicts of interest, and disciplinary actions. Executive Officers who provide investment advice to clients and representatives who advise clients must complete this form too.
- Code of Ethics
Filing a Code of Ethics ensures that your firm adheres to the standards set by the State of Tennessee.
- Client Advisory Contract
This contract must meet the appropriate regulatory authority standards for client advisory contracts imposed by Tennessee. It must also include the investment policy statement.
- Policies and Procedures Manual
This manual outlines the firm's internal procedures, including dealing with customer complaints and training new IARs. It also includes Business Continuity, Anti-money Laundering, Information Security, and Anti-insider Trading Plans.
To sum up, to register as an RIA in Tennessee, one must comply with financial statement requirements, earn specific professional designations, and submit necessary forms and documents. Starting an RIA may seem challenging, but it can be rewarding, and resources are available to assist you. Our team has created a complete RIA launch kit to aid in getting started.
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.