Thursday, April 14, 2011
Changes in firm definition
Answer: they must include the history (five years or since inception).
Why? Well, think about this: let's say, for example, that a manager of institutional and wrap fee accounts can't bring the wrap fee accounts into compliance today because they don't have the history, so they define the firm without them. Then, six months later they redefine themselves to include wrap; if they could just start from that point, this would be an easy way around the rules, yes? That would be a problem. And so, they need the history. Make sense?