The “Why” Behind the Recent Form ADV Amendments: What Information the SEC Will Require and How the Agency Intends to Use It

On August 25, 2016, the SEC adopted amendments to Form ADV that will become effective October 1, 2017. The amendments are designed to improve the depth and quality of information collected, to facilitate risk-monitoring initiatives, to assist the SEC staff in its risk-based examination program and to provide additional disclosure to investors and the public. In a guest article, Jeanette Turner, chief regulatory attorney and a managing director at Advise Technologies, provides an introduction to these recent amendments to Form ADV to help firms determine how to alter their internal procedures and processes. For additional insight from Turner, see “MiFID II Expands MiFID I and Imposes Reporting Requirements on Asset Managers, Including Non-E.U. Asset Managers” (May 28, 2015). On Thursday, May 11, 2017, from 12:00 p.m. to 1:00 p.m. EDT, Turner will expand on the thoughts in this article – as well as other ramifications of the recent amendments to Form ADV – in a webinar entitled “2017 Form ADV Changes,” which will be moderated by Rorie A. Norton, an associate editor of the Hedge Fund Law Report. Turner will be joined by fellow panelist Michael F. Mavrides, a partner at Proskauer Rose. To register for the webinar, click here. For further commentary from Mavrides on what investment advisers need to know about these SEC revisions to Form ADV and the recordkeeping rule, see our two-part series: “Managed Account Disclosure, Umbrella Registration and Outsourced CCOs” (Nov. 3, 2016); and “Retaining Performance Records and Disclosing Social Media Use, Office Locations and Assets Under Management” (Nov. 17, 2016).

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