What Is an Investment Adviser Representative (IAR)?
Unpack the essential role of an Investment Adviser Representative (IAR), their fiduciary duties, and the regulatory landscape.
Unpack the essential role of an Investment Adviser Representative (IAR), their fiduciary duties, and the regulatory landscape.
An Investment Adviser Representative (IAR) is a licensed financial professional who provides personalized investment advice and financial planning services to individuals and businesses. These professionals operate under the umbrella of an investment advisory company, working directly with clients to help them achieve their financial goals.
IARs engage in various activities to serve clients. They often build and design investment portfolios tailored to individual financial goals and risk tolerance. Their work involves researching and comparing different investment options, providing recommendations on securities, and offering advice on overall investment strategy. IARs also manage client accounts, which can include overseeing discretionary accounts where they make investment decisions on behalf of the client, as well as handling administrative matters such as ensuring proper funding for trades.
A central aspect of an IAR’s role is their fiduciary duty, which legally obligates them to act in the best interest of their clients. This standard requires IARs to prioritize client interests above their own and disclose any potential conflicts of interest. This commitment involves a duty of loyalty and care, ensuring that advice is disinterested and suitable for the client’s specific financial situation. Beyond investment management, IARs may also offer broader financial advisory services, including retirement planning, tax strategies, and estate planning, providing comprehensive guidance to their clients. For their services, IARs typically earn fees, which can be structured as a percentage of assets under management, flat fees, or hourly rates. In some cases, if also registered as a broker-dealer, they may earn commissions, but their advisory services remain subject to the fiduciary standard.
Investment Adviser Representatives operate within a structured regulatory environment overseen by both the Securities and Exchange Commission (SEC) and state securities authorities. The specific regulatory body depends on the assets under management (AUM) of the firm with which the IAR is associated. Generally, firms managing $100 million or more in AUM register with the SEC, while those below this threshold typically register with state securities regulators in their primary place of business. However, IARs are individually regulated by the state(s) in which they have a place of business or serve clients, irrespective of whether their firm is state or SEC-registered.
To qualify as an IAR, individuals must meet specific examination requirements. The Uniform Investment Adviser Law Examination, commonly known as the Series 65 exam, is the most frequent pathway to qualification in most states. This comprehensive exam assesses knowledge across various topics, including economic factors, investment vehicles, client investment strategies, and applicable laws and regulations, including fiduciary obligations. Candidates must answer 92 out of 130 multiple-choice questions correctly within three hours to pass, typically requiring a score of about 71%.
As an alternative to the Series 65, an individual can often qualify as an IAR by passing both the Series 7 (General Securities Representative Examination) and the Series 66 (Uniform Combined State Law Examination). The Series 66 exam is designed to combine elements of state securities laws and regulations, effectively covering aspects of both the Series 63 and Series 65 exams. Certain professional designations, such as Certified Financial Planner (CFP) or Chartered Financial Analyst (CFA), may also waive the examination requirements in many states. Once examination requirements are met, all IARs must be associated with a Registered Investment Adviser (RIA) firm.
The final step in the registration process involves the electronic filing of Form U4, the Uniform Application for Securities Industry Registration or Transfer. This form is submitted through the Central Registration Depository (CRD) system. Form U4 collects detailed information about an IAR’s employment history, disciplinary records, and background, which is then used to create individual records. While the RIA firm is responsible for submitting this form on behalf of the IAR, it is important for the IAR to ensure the information remains accurate and updated for any material changes.
A common point of confusion for those seeking financial guidance is the difference between an Investment Adviser Representative (IAR) and a Registered Investment Adviser (RIA). The distinction lies in their fundamental nature: an IAR is an individual, while an RIA is a firm or company. An RIA is the legal entity that registers with the Securities and Exchange Commission (SEC) or relevant state securities agencies to provide investment advisory services for a fee.
The IAR, conversely, is the individual financial professional who works for or is associated with that RIA firm. This individual is the direct point of contact for clients, providing the actual investment advice and managing client accounts on behalf of the registered firm. One way to understand this relationship is to consider an analogy: a Registered Investment Adviser is like a restaurant chain, and the Investment Adviser Representative is like the chef who prepares the meals and interacts with customers at a specific location.
While an individual can establish and own an RIA firm, they would still be registered as an IAR representing their own firm. The RIA firm holds the overall registration and bears the primary responsibility for compliance with regulatory requirements, ensuring that all operations adhere to established rules. The IAR, operating under the firm’s structure, provides the direct services and advice to clients. Both the RIA firm and its associated IARs are bound by a fiduciary duty, meaning they are legally obligated to act in the best interests of their clients at all times.