Securities Regulator Publishes Common ADV Deficiencies
The Texas State Securities Board has published the most common errors and deficiencies on submitted Form ADVs, causing comments and delays. The TSSB states that the most common errors result from inconsistencies among Parts 1 and 2 and the form Investment Advisory Agreement. The most common inconsistencies include the types of clients, compensation, fee schedule, and services. The TSSB also warns advisers to include non-assignment language in every advisory agreement and not to reference registration in marketing.