Who is NOT required to maintain and deliver a Supplement Brochure?

The correct answer indicates that personnel involved with client accounts for no more than 30 days are not required to maintain and deliver a Supplement Brochure. The reasoning behind this stems from the regulatory framework governing investment advisers and the specific requirements regarding the delivery of brochures.

Generally, the Supplement Brochure serves as an important disclosure document that provides clients with detailed information about the investment advisory services being offered. This includes qualifications, disciplinary history, and other critical factors that clients should be aware of when engaging an adviser. The requirement to provide this brochure is focused primarily on maintaining transparency and ensuring that clients have all necessary information to make informed decisions.

Personnel who interact with client accounts for an extended period, such as those exceeding 30 days, are more likely to be deeply involved in the advisory relationships and decision-making processes. Therefore, they bear a greater responsibility for providing relevant disclosures to ensure compliance with regulatory expectations. However, individuals whose involvement is limited to a shorter interaction, such as under 30 days, do not have the same ongoing fiduciary relationship and are thus not mandated to deliver a Supplement Brochure.

This distinction underscores the importance of engagement duration in determining disclosure obligations within the regulatory landscape for investment advisers, ensuring that clients receive relevant information from personnel who are actively involved