SEC Adopts Reforms Related to Investment Advisers Conducting Business Exclusively Over the Internet

2024-09-27 01:22:53

On March 27, 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments to the rules allowing certain internet-based investment advisers to register with the Commission (the "Internet Adviser Exemption").[1] These amendments will require investment advisers relying on the Internet Adviser Exemption to maintain an operational interactive website through which they provide digital investment advisory services to more than one client. Additionally, the amendments will require internet-based investment advisers to provide advice exclusively through an operational interactive website to all clients and make certain corresponding changes to Form ADV to qualify for the Internet Adviser Exemption.

Advisers relying on the Internet Adviser Exemption must comply with the rule, including amending their Form ADV by March 31, 2025, to include a statement that the adviser qualifies for registration under the Internet Adviser Exemption. Advisers that no longer qualify to rely on the amended Internet Adviser Exemption and have no other basis for registration must withdraw their SEC registration by June 29, 2025, by registering in one or more states and filing Form ADV-W.

[1] https://www.sec.gov/news/press-release/2024-36