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News September 13, 2004 Issue

DOL Gets With the IARD Program

If youíve got a state-registered adviser somewhere in your family tree that serves as an ERISA investment manager, listen up:

The Department of Labor (DOL) has changed the rules for how state-registered advisers must qualify as an investment manager. In a nutshell: submitting paper copies of Form ADV to DOL is no longer required. Instead, to qualify as an investment manager under ERISA, state-registered advisers simply must be registered with their state on IARD. DOLís adopting release, issued last month, noted that all but a few states require advisers to register via IARD, and those that donít still permit advisers to register on IARD if they wish (Wyoming does not have a state advisers act.)

The rule change is effective October 25, 2004. However, due to an interim relief provision included in DOLís proposing release, state-registered advisers have been able to rely on IARD to satisfy their investment manager notice obligation since December 9, 2003.

DOL estimated that 500 state-registered advisers would be affected by the rule change.