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

On October 1, 2017, significant changes went into effect to the Form ADV (October 2017 Amendments). In adopting those changes, the SEC sought to gather additional information from SEC-registered investment advisers regarding their managed accounts and other aspects of their advisory businesses to enhance the regulator’s ability to carry out its risk-based examination program. The October 2017 Amendments also offered groups of affiliated advisers operating a single advisory business a more streamlined approach to registering with the SEC using a single Form ADV. This two-part series outlines the lessons learned from those annual updating amendments filed by fund managers, with a focus on how managers dealt with the new disclosures required by the October 2017 Amendments. This second article explores the umbrella registration option available pursuant to 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. The first article examined the 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. For more on addressing the October 2017 Amendments to Form ADV, see “A Roadmap of Potential Landmines for Fund Managers to Avoid When Completing the Revised Form ADV” (May 25, 2017).

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