Information on the Registered Investment Adviser (RIA) process in Wisconsin is compiled in this easy to follow guide. Follow this guide to register an investment adviser (IA) firm or to become an investment adviser representative (IAR) for an existing firm.
This guide covers state registration through the Wisconsin Division of Securities in the Department of Financial Institutions as well as federal registration through the Securities and Exchange Commission (SEC).
Step 1. Get a Degree
Your professional and educational background information is made public through the Investment Adviser Public Disclosure (IAPD). Anyone searching for a licensed adviser can pull up the data and compare your credentials with those of other professionals in the field.
To ensure that you are a potential clients top choice, consider one of the following degree options:
- BA-Accounting
- BA-Consumer and Family Financial Services
- BS-Accounting
- MS-Finance
- MS-Accounting
- MS-Personal Financial Planning
- MBA –Finance or MBA-Accounting and Finance
- PhD-Finance
- PhD-Accounting
Certain courses can also benefit an advisor, these are:
- Business law
- Management
- Economics
- Computer information systems
- Taxation
- Ethics in business
- Accounting
- Marketing
- Finance
- Behavior of groups, persons, and organizations
- Statistics
- Quantitative applications applied to business
- Business communications
IARs should actively search for additional training and educational opportunities throughout their career. Professional certifications are not a requirement for licensure, but are recommended. To begin testing for a certification there are a couple things to look at. You must have either a bachelor’s degree or an acceptable amount of on the job training. Once these requirements are met, consider pursuing any of the following:
- Personal Financial Specialist (PFS)
- Chartered Financial Analyst (CFA)
- Chartered Financial Consultant (ChFC)
- Chartered Investment Counselor (CIC)
- Certified Financial Planner (CFP)
Step 2: Register Your Firm in Wisconsin
(This step is required when establishing a new IA firm. If your career will begin with an established firm, skip to Step 3.)
The Wisconsin Division of Securities regulates IAs with less than $100 million in assets under management. Federal SEC registration is required for management of anything over $100 million. In both cases, registration is done through the Investment Adviser Registration Depository.
- Complete the Entitlement Forms. One of the forms will cover the Super Accountant Administrator (SAA) designation requirements. The individual who is selected for this position will be granted access to the Firm Gateway and be allowed to complete the following steps.
- Fund the IARD User Account to cover state and federal fees. Fees to anticipate are:
- Exam fees for each IAR that will be in the firm
- Initially, you will pay a $225 filing fee for SEC-registered advisors; this includes firms with more than $100 million in assets under management
- IARs will be charged an $80 state IAR filing fee
- Wisconsin charges state-covered IA firms a $400 initial filing fee and federal-covered advisors a $200 fee
- Initial IARD set up fees for state registered investment advisors are currently being waived
- To outline the basic structure of a new firm, the Form ADV is used. This will include an explanation fee structure and investment philosophy. Form ADV is made available to prospective clients.
- Complete the Form U-4 Uniform Application for Securities Registration or Transfer for each IAR within the firm.
- Mail the following forms and required information to Wisconsin Department of Financial Institutions, 345 W Washington Ave, Madison, WI 53703:
- A completed copy of the Wisconsin Investment Advisory Activity of Applicant
- Samples of all client contacts
- Financial statements that show minimum net worth of at least $35,000 and a completed Financial Certification form
- A completed Designation of Supervisor form
- A list of branch offices, if any
Requirements to Transact Business in Other States
As a representative or principal of an RIA in Wisconsin, you are not limited to business in that state. You can seek clients in another state as long as you do not exceed the four client maximum. If you have a prospective fifth client in any one state, you are required to complete the registration process in that state and pay their fees with the firm’s IARD User Account.
According to the De Minimis Exemption, RIAs not currently registered in Wisconsin may conduct business in the state with up to four clients without being required to register. Registration in Wisconsin is required when a fifth client is added.
Step 3: Get Your Registered Investment Adviser License in Wisconsin by Taking the Required Exam
The amount of client assets managed by an RIA will determine the type of registration that is required, state or federal. The Wisconsin Uniform Securities Law applies to state registered firms managing less than $100 million in assets. Registration with The Securities and Exchange Commission (SEC) applies to firms managing more than $100 million in client assets. The following steps cover both scenarios.
Exam waivers are allowed to applicants who hold the following designations:
- Chartered Investment Counselor (CIC)
- Certified Financial Planner (CFP)
- Chartered Financial Analyst (CFA)
- Chartered Financial Consultant (ChFC)
- Personal Financial Specialist (PFS)
- Choose from the following exam scenarios:
OR
- Series 7, General Securities Representative Examination, which requires a sponsor and the Series 66, Uniform Combined State Law Examination.
Apply for exam(s) using one of the following forms:
- The registration application and the IAR exam application can be completed by submitting the Form U-4 Uniform Application for Securities Industry Registration or Transfer
OR
- All prospective IARs schedule their exams through one of their designated testing locations in Wisconsin (Prometric or Pearson Professional Center testing locations in Wisconsin. The maximum amount of time allowed to complete an exam after the registration process is complete in 120 days.
- The Prometric or Pearson testing locations recommend that you arrive an hour prior to the designated testing time.
- Test scores are released after the exam is complete.
Step 4: Ongoing Renewal and Update Requirements in Wisconsin
Investment Advisor Firm:
- IARD-specific renewal fees are $100
- Wisconsin’s renewal fees are $200 for both state and federal-registered firms and $80 for the IARs that are employed with the firm
- Form ADV updates are required once every twelve months
- License renewals are required by the December 31st deadline each year
- All renewal fees will be paid for each state the firm’s IARs are currently registered in
Investment Adviser Representatives:
If the Series 65 Exam has been completed, no additional continuing education will be needed.
An updated Form U-4 is required regardless of whether you operate as a sole proprietor or as a firm employee. The difference between the two is that a firm employee will provide their SAA with the documents that need to be updated in the system and a sole proprietor will update the information on their own. Form U-4 updates take place when changes occur to the following:
- Certifications
- Residential address
- Disciplinary action
- Name change (marriage)
- Educational background
- Civil judgments
- Client complaints
- Additional business activities
- Criminal record