A Roadmap to the SEC’s Proposed Changes to Form ADV

On May 20, the SEC proposed a number of significant changes to Form ADV and the rules under the Investment Advisers Act of 1940 (Advisers Act).  The changes to Form ADV have three primary goals: to fill in perceived data gaps; to facilitate “umbrella registration” for multiple private fund advisers that operate as part of a single advisory business; and to make certain technical and clarifying amendments.  The changes to the Advisers Act rules primarily expand certain of the “books and records” provisions and make certain technical amendments.  This article summarizes the proposed changes.  For more on Form ADV, see “Swiss Hedge Fund Marketing Regulations, BEA Forms and Form ADV Updates:  An Interview with Proskauer Partner Robert Leonard,” Hedge Fund Law Report, Vol. 8, No. 9 (Mar. 5, 2015).

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