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State Regulators to Require Licensing for Investment Adviser Representatives Displaced by COVID-19

Many investment adviser representatives (“IARs”) employed by or associated with state-registered and SEC-registered/“federal covered” investment advisers have been required to conduct business from their home or other temporary office location in the face of COVID-19. If those displaced IARs are not currently licensed by the states where they are temporarily providing advisory services, firms should quickly analyze whether they must license these individuals under the respective and applicable state law.

For example, the Pennsylvania Department of Banking and Securities recently announced that as of August 31, 2020, it would end its “grace period” for those IARs “who were displaced for teleworking to their PA home addresses during COVID-19” if they were previously unlicensed. We are also aware of other state regulatory bodies that have issued similar guidance and restrictions for IARs displaced from their principal office because of COVID-19.

COPYRIGHT © 2020, STARK & STARKNational Law Review, Volume X, Number 218


About this Author

The Stark & Stark Securities practice understands the legal and practical issues confronting investment professionals in providing advice and counsel for investment adviser regulations, security arbitration, litigation and enforcement, broker-dealer regulations, investment company and hedge funds, investment banking & venture capital and corporate governance. Attorneys in the Securities Practice Group include a former enforcement attorney from a state securities agency, a former mutual fund and broker-dealer compliance director and corporate secretary, and a member of the NYSE and...