Proper way to use your OSJ's LLC Name
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Trying to get situated here. I would like to use my OSJ's LLC name to put on signage and correspondence. I am also setting up my own LLC but will not be using my LLC's name for signage or correspondence. Do i need to fill out my OBA form with just my LLC or with my OSJ's LLC info too? Are there any other forms or filings I have to do? If I am way off base could you more seasoned guys point me in the right direction. Thanks. I am Lost here.
If you are part of a BD ask the compliance dept. They will have specific language to use.
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This is definitely a compliance question, and I have many years of compliance experience, but unfortunately I don’t think I understand your question. I guess where I’m not clear is you state you’re starting up your own LLC but will not be using your own LLC’s name for signage or correspondence. What kind of LLC exactly are you establishing? Is it independent, as in an independent RIA registered with the state, or a DBA name with your firm? The best suggestion I have is that you check with the BD’s Compliance Department, because ultimately it is their decision on how you can use their (the OSJ’s) name on signage and correspondence. If you are an independent RIA (perhaps you are a part of a hybrid platform?) you also have OBA disclosure requirements, but I am not clear on what “your own LLC” is and therefore can’t inform you on what those requirements may be. Please feel free to contact me if I can be of any assistance.
Managing Director, Polaris Compliance Consulting, LLC
Polaris Compliance Consulting, LLC Polaris Compliance Consulting, LLC
Polaris Compliance Consulting provides compliance services to Registered Investment Advisors of all sizes.
Several years ago when I was contemplating going independent, I initially thought I would be solo. I set up my own LLC. I subsequently joined an existing practice (OSJ) under their existing LLC. Having my own LLC has been worthwhile nevertheless. I have my paycheck routed through my personal LLC and it also provides tax advantages depending on how you file. I don’t believe it would hurt you regardless. My compliance departmetn does require that I have approval as an OBA. With that said, and as the others have mentioned, you should direct the question to your compliance department for their guidance.