Hi,
Perhaps I am either overthinking and misreading something but I have an inquiry in the “Disclosure” chapter; in particular, solicitors for state-registered vs federally-covered IAs.
I noticed this paragraph when discussing SEC covered IAs:
You may have noticed two big omissions from the state-based solicitor rule (emphasis mine). First, solicitors are not required to be registered as IARs. Second, there is no brochure delivery requirement for promoters. Given the adviser must provide the brochure to the client, the SEC felt forcing the solicitor to deliver it was redundant. As discussed above, the promoter must make disclosures at the time of solicitation. The SEC rule specifically states the disclosures must be made “clearly and prominently,” but does not explicitly require them to be put in writing.
It states that state-based solicitors aren’t required to be registered as IARs nor follow brochure delivery requirements for promoters as omissions. However, earlier in the chapter, it says solicitors for state-registered IAs must be registered as IARs for the firm they’re soliciting for and delivery two brochures (i.e. Form ADV Part 2A and solicitor’s brochure).
Am I missing something here?