Amendments To Form ADV: Practical Considerations

Beginning on October 1, 2017, all investment advisers filing Form ADV must use an amended version of Part 1A of the Form that contains several new and revised items.1 Among other things, the amended Form requires expanded information regarding the investment activities of separately managed accounts (“SMAs”), standardizes the registration of so-called “relying advisers” operating as […]

Revised Form ADV Began October 1st

Effective October 1, 2017, investment advisers must adhere to amended requirements regarding the investment adviser public disclosure form (Form ADV). The Securities Exchange Commission (the SEC) announced these amendments in 2016. The new Form ADV disclosure requirements apply to both initial and amended Form ADV filings. The amendments can be grouped into three categories: (i) additional […]

Funds Talk: October 2017 – SEC Issues Risk Alert Regarding Advertising Rule Compliance Based on Recent OCIE Examinations

On Sept. 14, 2017, the Securities and Exchange Commission (the “SEC”) issued a risk alert outlining certain compliance issues identified by the regulator’s Office of Compliance Inspections and Examinations (“OCIE”) related to Rule 206(4)-1 (the “Advertising Rule”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The compliance issues addressed in the alert were […]