Lessons Learned From How Advisers Dealt With the October 2017 Amendments to Form ADV (Part One of Two)

On October 1, 2017, sweeping changes went into effect to the Form ADV (October 2017 Amendments). The 2019 Form ADV season marks the second time that advisers will be providing the information required by the October 2017 Amendments. Although the process should be smoother this time around, fund managers must be consistent with the approaches and methodologies that they used in last year’s filing. This two-part series outlines the lessons learned from the annual updating amendments filed by fund managers in March 2018, with a focus on ways managers dealt with the new disclosures required by the October 2017 Amendments. This first article examines key takeaways from last year’s filings, as well as the detailed disclosures that advisers are now required to provide with respect to managed account clients and their other office locations. The second article will explore the umbrella registration option available through the October 2017 Amendments, as well as the new disclosure requirements relating to a fund manager’s use of social media, regulatory assets under management by client type and chief compliance officer. See our two-part series on the October 2017 Amendments to Form ADV and the recordkeeping rule: “What Investment Advisers Need to Know About Managed Account Disclosure, Umbrella Registration and Outsourced CCOs” (Nov. 3, 2016); and “What Investment Advisers Need to Know About Retaining Performance Records and Disclosing Social Media Use, Office Locations and Assets Under Management” (Nov. 17, 2016).

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