The State of New York recently announced a special exam waiver window on the Central Registration Depository (“CRD”) system, which will affect existing investment adviser representatives (“IARs”) seeking registration in New York via an exam waiver (in lieu of taking and passing the Series 65 or Series 66 & 7 examinations). IAR applicants requesting an exam waiver should apply between February 27, 2021 and August 31, 2021 in order to avoid opening an unnecessary exam window on the CRD system and being charged an examination fee. Between Feb. 27, 2021 and August 31, 2021, FINRA will temporarily modify the CRD system for NY only RA registration requests to allow the applicants who qualify for an exam waiver to avoid opening a window.

Investment adviser representative applicants who do not qualify for any waiver under 13 NYCRR 11.7 must open an exam window and pass the required exam(s). Failure to request an examination window when one is required can lead to significant delays to the investment adviser representative registration application.

As a reminder, any individual who is already serving in the capacity as an investment adviser representative (an “existing investment adviser representative” as defined by below) must submit a Form U4 requesting investment adviser representative registration in New York for that person on or before August 31, 2021 in order to maintain eligibility to continue providing investment advisory services during the implementation period that ends December 2, 2021. New York considers an “existing investment adviser representative” to be any individual who, prior to February 1, 2021, was serving continuously and permissibly in any capacity that requires investment adviser representative registration, and who, through continued service, is subject to the registration requirements. The rule change does not provide any relief to individuals who were acting as investment adviser representatives in violation of New York law prior to February 1, 2021.

For more information, click here to read New York’s recently updated Investment Adviser FAQs.

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Sample Forms

Sample Compliance Manual Section – IAR Licensing in New York

New York Adopts Investment Adviser Representative Registration Rule – December 7, 2020

Proposed Rule to License New York Investment Adviser Representatives – April 15, 2020

New York Investment Advisor Firm & Investment Adviser Representative State Registration Requirements

Form U4 FAQs

Frequently Asked Questions – Series 65 Examination