The firm’s CCO shall be responsible for handling the hiring, registration if required, and training of IARs and unregistered members.

Onboarding

The firm’s CCO will:

• Conduct due diligence checks to ensure new advisors will not pose compliance or regulatory problems;
• Verify whether or not the activities of new members will require registration as “IARs” in any jurisdiction;
• Verify whether or not the activities of new members will require them to be considered access persons for compliance with personal securities transactions requirements;
• Review outside business activities of new members; and
• Collect attestations that they have read and will abide by CP’s Policies and Procedures Manual, Code of Ethics, Privacy Policy, Cyber-Security, and any applicable corporate policies.

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Core Planning is an SEC registered investment adviser. The Firm distinguishes between firm-level state notice filing obligations and individual IAR state registration obligations.

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Firm-level state notice filing obligations

SEC-registered investment advisers (RIA) must submit a notice filing in any state where they have a place of business or six-or more clients within a 12-month period. With the exception of certain states (e.g., Texas, Louisiana, New Hampshire and Nebraska) which may require notice filing before engaging with a single client in the state, regardless of the number of clients or presence of an office in the state. The Firm will monitor and maintain required notice filings in states where the Firm’s advisory activities or client relationships trigger a filing requirement. The Firm will periodically review the Firm’s notice filing states and update as necessary.

Individual IAR state registration obligations

Per NASAA guidance, each IAR will generally be registered in the state or states in which the IAR maintains a place of business and/or residence where the IAR regularly provides advisory services, solicits, meets with, or otherwise communicates with clients, or any other location held out to the public as a place where the IAR does those things. The existence of clients in a particular state does not, by itself, necessarily require every IAR serving those clients to be individually registered in that state. IARs are to review, confirm, and update the states they are registered in on a periodic basis.