SEC Proposes Amendment to Form ADV

The SEC is consulting on amendments to Form ADV that will affect both SEC registrants and Exempt Reporting Advisers alike.

Release IA-4091, published on 20th May, proposes significant amendments to Form ADV regarding:

  1. Separately Managed Account disclosure;
  2. Umbrella Registration for relying advisers;
  3. Additional information disclosures from investment advisers including information on social media, the advisers own assets, and clients.

In the same release, the SEC is proposing changes to two books and records rules, Rule 204-2(a)(16) and Rule 204-2(a)(7). The SEC believes the changes to Rule 204-2 will be useful in examining and evaluating adviser performance claims, a point the SEC has highlighted as an examination priority for 2015.

The SEC also proposes withdrawing many transition rules enacted in 2011 relating to adviser registration.

The proposals are expected to be adopted and will require investment advisers registered with the SEC to collect and disclose significant data on their Form ADV.

The SEC invites comments on some or all of the questions posed within the release. Further information concerning the proposed changes can be found on our website via the link provided.


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