Our “turn-key” investment adviser registration program for the State of Ohio includes:

• Setting up your firm’s account on the Investment Adviser Registration Depository (IARD) system
• Acting as liaison with the Ohio Division of Securities
• Facilitating the payment of all Ohio state registration fees
• Preparing and filing Form ADV Part 1 via the IARD system
• Preparing and filing Form ADV Part II via the IARD system
• Drafting and filing investment advisory and/or financial planning agreements
• Drafting a compliance manual in conformity with the Ohio Administrative Code
• Drafting of the privacy notice
• Filing Form U4 for investment adviser representatives
• Facilitating the filing of the Ohio Fingerprint Card

Important Additional Information for Ohio Registrants:

Compliance Requirements

All Ohio-registered investment advisers are required to adopt, and implement, written policies and procedures reasonably designed to prevent violations by the adviser or its supervised persons of the Ohio Securities Act and rules. All investment advisers must designate an individual who will be responsible for administering these policies and procedures. This individual must be a supervised person. There are no exceptions to these rules for small investment advisers, even if the adviser is run by a single individual. The books and records provisions have also been amended to require that all advisers keep current copies of their new policies and procedures, and copies of all records documenting their annual review of the same. Ohio’s rules are virtually identical to the SEC Compliance Rule.

In keeping with the requirements of the SEC Compliance Rule, all Ohio-registered investment advisers must: (i) adopt and implement policies and procedures reasonably designed to prevent violations of state securities laws; (ii) review the policies and procedures at least annually to determine their adequacy and effectiveness of their implementation; and (iii) designate a chief compliance officer responsible for administering the policies and procedures.

At a minimum, an investment adviser registered in Ohio must adopt and implement written policies and procedures that address the following areas of compliance concern:

• Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the adviser, and applicable regulatory restrictions;
• Trading practices, including procedures by which the adviser satisfies its best execution obligation, uses client brokerage to obtain research and other services ("soft dollar arrangements"), and allocates aggregated trades among clients;
• Proprietary trading of the adviser and personal trading activities of supervised persons;
• The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements;
• Safeguarding of client assets from conversion or inappropriate use by advisory personnel;
• The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction;
• Marketing advisory services, including the use of solicitors;
• Processes to value client holdings and assess fees based on those valuations; 
• Safeguards for the privacy protection of client records and information; and 
• Business continuity plans.

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Please call us toll free at 888-798-2930 for more information about our Ohio “Turn-Key” Registration Program.