firm registration & filings.

Core Planning, LLC is a registered investment adviser in the State of Missouri.


Policy

It is the firm’s policy to maintain compliant registration status at all times. This may require additional state registrations in other appropriate jurisdictions as required.

Unless otherwise permitted, Core Planning will not conduct investment advisory activity in any jurisdiction unless the firm is first registered in that jurisdiction. While most jurisdictions will allow for a “de minimis” number of clients before requiring firm registration, some jurisdictions may require registration upon taking on the first client in that jurisdiction.

Having a “place of business”, as defined by applicable regulatory statutes, in a state will require registration regardless of the number of clients in that jurisdiction.

It is the CCO’s responsibility to ensure that the firm is appropriately registered at all times.


Procedure
The firm’s CCO will:

  • Monitor the state of residence of its clients to ensure the firm does not exceed the de minimis threshold for any jurisdiction;

  • File updated applications to request additional state registrations when needed; and

  • Complete the application process so as to ensure the firm becomes registered in the necessary jurisdictions.


Renewal
The firm’s CCO will ensure that:

  • The firm’s annual renewal fees are timely paid through the IARD system every calendar year as required;

  • The firm files its Form ADV Annual Amendment within 90 days of its fiscal year end; and

  • The firm provides any additional paperwork or other information required on an annual basis in connection with the firm’s annual renewal filings.

Other-than-Annual Amendments

The firm’s CCO will ensure that the firm files material changes to its Form ADV and any Form U4 documents promptly, usually within 30 days if firm’s disclosure brochure becomes materially inaccurate.

Firm Policy
It is the firm’s policy to make the necessary filings. It is the CCO’s responsibility to be familiar with the various filings and to ensure that the firm has made the appropriate filings in a timely manner.


Specific Filings
Some of these filings with a brief description include:

  • Section 13(d) – Requires a Schedule 13D to be filed by the beneficial owner of more than five (5) percent of a publicly traded equity security (Section 12). It is important to understand the broad definition of “beneficial owner” and the timing of the report, which has to be filed within 10 days of the purchase;

  • Section 13(f) – Requires advisers to file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities. Form 13F usually has to be filed within 45 days of the end of the quarter;

  • Section 13(g) – Requires a filing similar to a Schedule 13D, but with less information. May be allowed if the investor is strictly a passive investor and does not intend to exert control;

  • Section 13(h) – Requires an adviser that is defined as a “large trader” to file its first Form 13H within 10 days of meeting the threshold. Large traders are also required to amend Form 13H annually within 45 days of the end of the year and make quarterly update filings. A large trader is a person or entity whose trades exceed either (i) two million shares or $20 million in a day or (ii) 20 million shares or $200 million during any calendar month;

  • Section 16 – Requires directors, officers, and shareholders of more than ten (10) percent of a publicly traded company to file various reports based on activity, specifically: Forms 3, 4 and 5.

If the CCO at any time determines that the firm needs to make one of these regulatory filings, it may be helpful at that time to consult with a qualified attorney or third party to help with the filing.