Under the Dodd-Frank law, most Registered Investment Advisers (RIAs) with assets under management (AUM) below $100 million will soon be required to withdraw SEC registrations and register with the state where their primary office is located. The SEC has estimated that 4,100 RIAs must make this change, and time is of the essence.
All RIAs who are SEC-registered as of July 21, 2011, must amend their Form ADVs by August 20 to report the market value of assets under management. By October 19, 2011, any RIAs who are not eligible for SEC registration must switch to state registration, or else the SEC will cancel their registrations. There is one significant exception: Advisers with AUM exceeding $25 million may choose to stay with the SEC, if they are required to be registered in more than 15 states.