MarketCounsel’s RIA Incubator program is a comprehensive suite of services specifically designed to provide prospective registered investment advisers with the consulting they need, fulfill their registration obligations, and install an initial compliance program. Beyond just basic registration services, firms enrolled in the RIA Incubator program receive a custom, yet process-driven solution to their initial regulatory and compliance challenges, delivered by a focused and highly-skilled team of compliance professionals and backed by a team of dedicated and experienced administrators. MarketCounsel commits up-front to a true fixed fee for its services, enabling you to accurately budget for this project with absolute financial certainty. Transparency and honesty in our pricing, combined with the unique, time-tested features of the RIA Incubator program and our extraordinary personal service, distinguish MarketCounsel as an unparalleled value for investment adviser startup projects.
THE RIA INCUBATOR PROCESS
The RIA Incubator program is custom-tailored to the unique needs and challenges of each client, but often includes:
- Extensive business and regulatory consultations with our professional staff.
- Complete Investment Adviser Registration Depository (IARD) and Central Registration Depository (CRD) entitlement and administration. In fact, you’ll never have need to access these filing systems yourself.
- Researching state securities registration requirements using our in-house reference library and proprietary database. We never rely solely upon a general understanding of complex securities regulations. We understand that it’s sometimes just as important to determine where not to register as where to register.
- Preparation of Form ADV (including all applicable schedules, both electronic and paper) to accurately correspond with and represent your firm’s intentions as discussed in prior consultations and as outlined in your business plan.
- Preparing a wrap brochure if you desire to be the sponsor or portfolio manager of a wrap program.
- Preparing registration forms for each proposed investment adviser representative, after confirming each proposed individual’s obligation to register.
- Performing all electronic regulatory filings for your firm (Form ADV Part 1) and its representatives (Forms U4) with the U.S. Securities & Exchange Commission (SEC) and/or the appropriate state securities regulators.
- Performing all paper regulatory filings and disclosure forms (including Form ADV Part 2) for your firm and its representatives with the U.S. Department of Labor and/or the appropriate state securities regulators.
- Monitoring filings through regular and constant communication with the appropriate examiners. We do not wait for the regulators to respond. Our team proactively checks registration status every morning and remains in constant communication with examiners until your registration is approved.
- Responding to any and all deficiencies in filings until cured (if necessary).
- Reviewing proposed stationery (business cards / letterhead) and advertising (websites, brochures, etc.) to ensure compliance with relevant securities regulations including any appropriate disclosures. We are deeply knowledgeable about federal, state and self-regulatory organization (if applicable) advertising rules, and regularly help our clients to effectively get their message across in a compliant manner.
- Developing a set of custom-drafted policies and procedures that fits your proposed business operation along with corresponding forms for their efficient implementation. Policies and procedures are not a “one size fits all” solution. Rather than doing what’s easiest for us, we choose to identify the policies and procedures that each client’s business needs, so that you do not incur deficiencies for failing to live up to a compliance manual that is excessively onerous for the needs of your firm. Simply put, we never raise the bar on our client’s compliance efforts in order to ease our own burden.
- Furnishing a Business Continuity Planning Workbook to document preparedness in the event of a disaster or loss of key personnel. While this plan has become a regulatory requirement for most jurisdictions, we have created a critically-acclaimed workbook that goes well beyond compliance, in an effort to help you plan for the worst.
- Delivering a Data Security Planning Workbook to evidence compliance with state and federal privacy rules and data security regulations. We have created a user-friendly workbook that goes beyond the compliance requirements to ensure you (and your clients) are protected from potential data loss.
- Providing tools for the installation of your firm’s initial compliance program including comprehensive, action-oriented information on books & recordkeeping responsibilities and a comprehensive set of practice management tools including forms, letters, etc.
- Access to MarketCounsel’s In the Loop subscription service to obtain an instant boost to your library of relevant industry publications.
- Electronic versions of the aforementioned documents in a non-proprietary format, without ever needing to ask for them.
- A discount offer for membership into MarketCounsel’s RIA Institute for Compliance Management, allowing us to effectively provide proactive and reactive ongoing regulatory and compliance services as your outsourced compliance department.
Of course, RIA Incubator participants may opt to supplement the core program with an array of options available exclusively to them. Each proposal for engagement is determined only after a detailed professional consultation, and may vary. Certain terms of engagement and restrictions apply.
Special Editions and Upgrades
Breakaway Broker Edition
The RIA Incubator Breakaway Broker Edition adds a set of processes to our standard RIA Incubator Program, providing a multi-part strategy aimed at helping you to avoid early detection of any outside business activities by your current employing firm. For many candidates, this edition provides a much desired means to effectively “fly under the radar.”
The RIA Incubator Undercover Edition is intended for candidates who require the ultimate in anonymity and discretion. Undercover is an exclusive offering by MarketCounsel in conjunction with its affiliated law firm, to perform services which would enable you to “acquire” the investment advisory firm upon successful organization, formation, and registration. In the meantime, legal counsel would effectively “stand in” and build the company consistent with your vision.
Hedge Fund Manager Edition
The RIA Incubator Hedge Fund Manager Edition adds a set of services specifically tailored for a hedge fund manager registering as an investment adviser.
The RIA Incubator Program FastTrack upgrade includes all of the core program services, but delivered on a much more aggressive and attentive timetable. It provides for priority “move to the head of the class” treatment in all phases of our initial engagement.
Wrap Fee Upgrade
A wrap fee program is required for advisers who plan to bundle advisory services with transaction fees, and charge clients a single combined fee. Becoming a wrap fee program sponsor may also provide you with additional flexibility in marketing and administering your advisory business. If your business model provides for this type of fee arrangement, MarketCounsel will develop the required separate “brochure” to be delivered to your clients along with corresponding regulatory forms to be maintained and potentially filed with securities regulators.