Part 2A Should Not be Considered Filed With the Commission. Legg Mason commends the Commission for this reasonable approach. To the contrary, it will burden advisers for no reason. The Commission is the sole registration authority with jurisdiction over federally registered advisers. The Commission has determined that it does not need a copy of Part 2A for every federally registered adviser until the IARD can accept Part 2A electronically.
States have no authority to register federally registered advisers.
Yet, the states have requested a special accommodation to enable them to receive more disclosure information from federally registered advisers than will be received by the Commission. The states do not need this information. Many federally registered advisers, including Legg Mason's subsidiaries, do business in many states. Like Legg Mason's subsidiaries, many also provide substantially different types of advisory services and will prepare multiple brochures. The requirement to file hard copies of these materials and all amendments thereto with the states will impose material administrative and financial obligations on advisers for no reason.