Text or WhatsApp(808) 600-9260

Home / Questions / How can a family review a multifamily office’s regulatory examination history?

How can a family review a multifamily office’s regulatory examination history?

Short answer

Start with the firm’s legal name and regulatory registrations. Search the SEC’s Investment Adviser Public Disclosure database, review Form ADV filings and disclosures, and check FINRA BrokerCheck when brokerage services are involved. Ask the firm for examination letters, deficiency responses, and remediation records, recognizing that regulators generally keep examination work confidential.

Search the public regulatory record

First, identify the exact legal entity that provides advice. A multifamily office may use several related companies, so confirm names, registration numbers, and states. Search the SEC’s Investment Adviser Public Disclosure database, or IAPD. It provides Form ADV filings, registration status, professional background, and reported disciplinary disclosures for advisers and representatives. [1]

Read Form ADV Part 1 for ownership, affiliates, business activities, and disciplinary answers. Read Part 2A, the firm brochure, for services, fees, conflicts, custody practices, and disciplinary information. Read Part 2B supplements for the background and disciplinary history of specific supervised people who advise the family. The SEC requires these brochures and supplements to present information in plain English. [2]

Check broker and state records

If the office or its staff also operate through a broker-dealer, search the firm and relevant individuals on FINRA BrokerCheck. The report can show employment history, licenses, investigations, disciplinary actions, customer disputes, civil proceedings, liens, bankruptcies, and certain terminations. FINRA also provides a separate disciplinary-actions database. [3]

Confirm state registrations through links provided by IAPD or through the relevant state securities regulator. State records can add information for state-registered advisers and representatives. Keep the search focused on the entities and people who will actually manage money, select managers, provide advice, or control custody.

My advice would be to never work with an attorney that hasn’t worked with at least 20 families that are worth over $50M.

Richard C. Wilson, Family Office ClubThe Single Family Office, a book by Richard C. Wilson

Ask for what databases cannot show

A public search will not usually reveal a complete examination file. SEC materials state that investment adviser examinations are confidential. A clean public record therefore does not establish that no examination occurred or that every issue was minor. [4]

Ask the office for the date and scope of its latest SEC or state examination, the closing letter, any deficiency letter, and a written summary of corrective actions. Ask whether all items were closed and who verified completion. Request explanations for any disclosure, settlement, complaint, or ownership change. Compare the answers with the public filings, then document the names searched, dates reviewed, and questions still open. This is educational due diligence, not legal, tax, or investment advice.

Sources

  1. Investment Adviser Public Disclosure (IAPD), Investor.gov
  2. Investor Bulletin: Amendments to Form ADV, U.S. Securities and Exchange Commission
  3. Using BrokerCheck, Investor.gov
  4. Regulation of Investment Advisers, U.S. Securities and Exchange Commission

Ask Richard

Have a question about multifamily offices, fees or how to compare firms? Richard C. Wilson has run Family Office Club since 2007 and answers reader questions directly.

Send a question Text or WhatsApp (808) 600-9260