​​​​​​Investment Advisory Services

If the broker-dealer intends to provide investment advisory services for compensation as part of its regular business but not through a subsidiary or affiliated company, it must file for a separate registration or notice filing depending on whether the firm is a federal covered investment adviser or a state-registered investment adviser.

For federal covered advisers making their first notice filing, the broker-dealer must make a notice filing on Investment Adviser Registration Depository (IARD) and amend its Form BD application “Types of Business.” The fee for a notice filing is $200. There is no review of the notice filing other than for branch office information.

Any agent of the broker-dealer who intends to provide investment advisory services for the broker-dealer/investment adviser must be registered as an investment adviser representative of the federal covered adviser. A person who will only provide advisory services and not sell products to customers is permitted to only register as an investment adviser representative for the federal covered adviser but not as an agent of the broker-dealer. See Investment Adviser Representative​ for more information.

If the broker-dealer will also conduct activity as a state-registered adviser, the broker-dealer must file an application for registration as an investment adviser via the IARD and file an amendment to its Form BD application “Types of Business.” The fee for initial registration as a state investment adviser is $400 ($200 for the review of the application and $200 for the registration fee). Any agent of the broker-dealer who intends to provide investment advisory services for the investment adviser must be registered as an investment adviser representative of the state-registered adviser. See the Investment Adviser Guide and Inv​estment Adviser Representative​ for more information.

Broker-dealers offering investment advisory services as state-registered investment advisers must comply with investment adviser recordkeeping and other requirements as described in the Investment Adviser Guide.