Web CRD enhances functionality relating to branch offices

August 15, 2007 -

Web CRD enhances functionality relating to branch offices

Beginning on October 31, 2005, Web CRD enhanced its functionality relating to branch offices. This functionality will provide advisers with a uniform electronic branch office submission process for registering, amending and closing branch offices. As a result of this enhanced functionality, certain registered investment advisers must file one or more Form BR(s) via IARD where the adviser maintains branch offices.

This new Web CRD functionality will not apply to SEC-registered investment advisers, even if they maintain branch offices. For now, SEC-registered advisers do not need to worry about the Form BR and must report branch offices as they have done in the past. Furthermore, many states will not use Web CRD for this year’s branch office renewal processing.

In response to this enhancement, NCS has begun reviewing the Schedule D of its retainer clients to determine if they maintain branch offices. In those situations where a Form BR must be filed, NCS will handle these filings on behalf of its retainer clients. If you maintain a branch office that is not currently reflected on your Schedule D, please notify NCS so that we may update your records.

The Florida Office of Financial Regulation recently began notifying investment advisers of the change in the process for filing their branch office submissions. Unfortunately, these letters were sent to all investment advisers, even if they are SEC-registered or have no branch offices. If you are SEC-registered or have no branch offices, there is no need to contact NCS or take action in response to these letters.

Other states with branch office registration requirements may soon contact advisers regarding the new process. Once again, if you are SEC-registered or have no branch office, there is no need to contact NCS or file a Form BR.