Considerations for Solicitors and References

Considerations and references for solicitors:

We will provide disclosures to referred clients regarding the solicitation arrangement, including the amount of compensation you will receive.

Are you ineligible to solicit clients due to disqualifying events in your past? Refer to https://www.ecfr.gov/current/title-17/chapter-II/part-275/section-275.206(4)-1.

As a solicitor, you may be subject to statutory or regulatory requirements under Federal law, including the requirement to register as an investment adviser pursuant to the Adviser’s Act of 1940. Refer to https://www.sec.gov/about/divisions-offices/division-investment-management.

As a solicitor, you may be subject to registration under state law, including any applicable licensing requirements applicable to individuals.

For New York State refer to https://ag.ny.gov/investment-advisers-faq.

For New Jersey refer to https://www.njconsumeraffairs.gov/bos/bosforms/Instructions4-Investment-Advisers-and-Investment-Adviser-Representatives.pdf.

For Connecticut refer to https://portal.ct.gov/DOB/Securities-Licensing/Investment-Adviser-Agents/Instructions-for-Investment-Adviser-Agent-Registration-in-Connecticut.

For Massachusetts refer to https://www.sec.state.ma.us/divisions/securities/rice/investment-advisers-representatives.htm and https://www.sec.state.ma.us/divisions/securities/rice/rice-faqs.htm.

For National American Securities Administrators Association refer to https://www.nasaa.org/industry-resources/investment-advisers/state-investment-adviser-registration-information/.