Regulatory Update: State Regulators Revisit Temporary Relief for Investment Advisor Registrants Affected by the COVID-19 Pandemic

Several states adopted measures granting temporary relief to investment advisor registrants affected by the COVID-19 outbreak. This ‘temporary relief’ allowed employees to telework from home or work from another temporary office location without complying with local licensing requirements. Many state regulators that issued these temporary orders have since updated their guidance to end the ‘grace period’ or indicate the date that the order will expire. State and federally covered investment advisors may be impacted by these deadlines if they have investment advisor representatives working from states that will require compliance with the local registration requirements. Advisors should review whether they have employees, or even clients, relocated to another jurisdiction that may cause additional IAR registrations, state registrations, notice filings, or branch office disclosures (for permanent moves).

Since the COVID-19 related restrictions can fluctuate daily, no set list or website can be relied upon for accurate information on every state. Where guidance is not clear, contacting the state’s Securities Division may be the best route for up-to-date information.

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