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General Questions |
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So is this the initial registration fee or a renewal? |
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The Questionnaire is separate from your registration or renewal; there are no fees involved. |
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Is it mandatory? |
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Yes, it's mandatory. |
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I became registered with the State of Michigan in 2008. Do I need to complete the Questionnaire? |
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No, only Registrants who have been operating for the entire calendar year are required to complete the Questionnaire. |
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If I do not receive a confirmation e-mail should I mail in a printed copy of the submitted Questionnaire? |
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No, but keep a copy for your records in case the Office later questions whether or not you completed the survey. |
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Will information that I submit
also update the information on lARD? |
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No, completion of this Questionnaire in no way changes any information filed on the lARD. You will still be responsible for the usual updating of any information on the lARD. |
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Will information that I submit also update the information on my Part II of Form ADV? |
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No, completion of this Questionnaire in no way changes any information filed on your Part II of Form ADV. You will still be responsible for the usual updating of any forms filed with the Office, including Part II of Form ADV |
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What if the information I submitted later changes? Do I have to go back and change my Questionnaire answers? |
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If an error was made, you should resubmit the Questionnaire, however, you do not have a duty to constantly update your Questionnaire answers. You are responsible for providing information that is accurate as of the date the Questionnaire is completed. |
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I won't be able to complete the Questionnaire by the June 1, 2009 deadline. What must I do to get an extension? |
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Requests for extensions will be reviewed on a case-by-case basis. The Registrant must submit the request with explanation to ofis-sec-info@michiqan.qov for consideration. |
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What are some common errors in completing the Questionnaire? |
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There are several easily preventable mistakes, including:
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Using an Agent or Broker-Dealer's CRD number instead of the Adviser's IARD number.
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Adding dollar signs, commas, parentheses and/or decimal points to responses in questions 8 and 9, regarding certain financial information. (Negative numbers should use a minus sign to designate they are negative, thus, a net loss of a thousand dollars should be entered as: "-1000".
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Advisers With No Clients |
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My Investment Adviser registration is inactive, i.e., I have no clients and am not seeking new clients. Do I have to complete the Questionnaire? |
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Yes, you do as you are currently registered with the State of Michigan. Additionally, if an OFIS examiner visits you, you must provide all of the records normally required of an Adviser who is "active." |
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Finders |
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I'm an Investment Adviser acting as a Finder. Do I have to complete the Questionnaire? |
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Yes. |
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Hedge Funds |
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I'm an Adviser to a hedge fund. For question 6, regarding the total number of clients for the Adviser, do I answer ‘1' for the hedge fund or do I look through to the number of people invested into the fund |
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Michigan has taken the position that each investor in a hedge fund should be counted as a client of the Registrant, thus look through to the number of people invested into the fund.
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Insurance Agents |
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I'm a representative for an Investment Adviser. I'm also a licensed insurance agent. Does this qualify as an affiliation with an Insurance Company as asked by question 14? |
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No. |
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SEC Registered Investment Advisers |
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Do I need to complete this Questionnaire if I'm an SEC Registered Investment Adviser? |
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The Investment Adviser Annual Questionnaire needs to be completed by Investment Advisers registered with the State of Michigan; SEC registered firms that notice file with the State of Michigan are not to complete the Questionnaire. |
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Third Party Arrangements |
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Question 15 asks about ‘third-party arrangements.' Would you give me an example of such an arrangement outside of questions 16 and 17? |
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An Adviser has a client named Mr. Smith. The Adviser has concluded that portfolio manager ABC should manage 30% of Smith's portfolio, and portfolio manager XYZ should manage 70%. This is an example of a third-party arrangement outside of a typical finder/solicitor relationship. |
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Withdrawn Advisers |
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I was registered with Michigan last year, but I've decided to withdraw my Investment Adviser registration. Do I have to complete the Questionnaire? |
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No, however, your ADV-W must be submitted by June 1, 2009. |
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Written Policies and Procedures |
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Question 3 asks about written policies and procedures. As a State registered Adviser, am I required to have written policies and procedures? |
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It is strongly recommended that an Adviser have written policies and procedures in place. If the Adviser is sued, a common issue will be whether the Adviser's policies and procedures were consistently followed. It places the Adviser at a significant disadvantage if the Adviser has no written policies and procedures in place. It makes good business sense. |
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