Banking Commissioner Reminds Exempt Reporting Advisers of their Form ADV State Filing Obligations

June 23, 2017

As a follow up to prior notices, Banking Commissioner Jorge Perez would like to remind investment advisers relying on the Connecticut Exempt Reporting Adviser (ERA) exemption to review their form filings and ensure that any deficiencies are corrected no later than June 30, 2017. 

Investment advisers relying on the state ERA exemption must complete the Form ADV items prescribed by the Securities and Exchange Commission.  Currently, the requirements consist of Form ADV Items 1, 2, 3, 6, 7, 10 and 11 of Part IA, as well as corresponding schedules.  Per federal requirements, new ERAs must file within 60 days of becoming an ERA.  As a reminder, the filing requirements are set forth in 17 CFR 275.204-4. 

“The Department of Banking issued a notice in March, advising the investment advisory community of this approaching deadline,” said Commissioner Jorge Perez.  “The Department had also reached out to legal practitioners by various means to help disseminate this information to exempt reporting advisers.  Today’s notice is an additional reminder to help ensure compliance by industry professionals.”

For additional background information, please refer to the filing notice.