SEC Extends Record-Keeping Rules for Multi-State Investment Advisers
Published Date: 4/13/2026
Notice
Summary
The SEC is asking to extend the paperwork rules for certain investment advisers who register with the Commission because they work in 15 or more states. These advisers must keep records for five years and update their registration if their situation changes. This extension keeps things clear and fair without adding new costs or deadlines.
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Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
Estimated Annual Compliance Burden and Cost
The SEC estimates 122 advisers will respond annually, with an estimated 8 hours per response and a monetized time burden of $3,024 per response (aggregate monetized burden $368,928). The SEC estimates $0 in non-time cost burdens.
SEC Registration Allowed for 15+ State Advisers
If you are an investment adviser that would otherwise be required to register in 15 or more states, Rule 203A-2(d) lets you register with the SEC by indicating that status on Schedule D of Form ADV. The rule is the exemption that permits registration with the Commission for advisers meeting the 15-or-more-states threshold.
Ongoing Paperwork and Recordkeeping Duty
If you rely on Rule 203A-2(d), you must indicate on Schedule D of Form ADV that you conclude you are required to register in 15 or more states and include an undertaking to withdraw registration if you later report you are no longer required to register in 15 or more states. You also must keep, for five years after each Form ADV filing, an easily accessible record of the states in which you determined you would be required to register but for the exemption.
Withdrawal Filing Deadline if No Longer Eligible
If you indicate on your annual updating amendment that you are no longer required to register in 15 or more states, you must withdraw your SEC registration by filing Form ADV-W within 180 days of the adviser's fiscal year end.
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