The SEC initiated a record number of enforcement actions in fiscal year 2011.  Among other things, the SEC has focused more attention on ferreting out false and misleading statements made by investment advisers in communications with investors and regulators.  As recently as November 2011, Robert Khuzami, Director of the SEC’s Division of Enforcement, explained that the SEC is specifically targeting investment advisers that it suspects may have filed Forms ADV containing false or misleading statements.  This article describes a recent SEC action indicating that the agency will bring enforcement actions based on allegations of inaccuracies in Form ADV.  This article also makes recommendations that hedge fund managers can implement to avoid Form ADV-related violations.  For a discussion of another current SEC enforcement initiative, see “Hedge Fund Managers with Unexplained Aberrational Performance Are More Likely to Become Targets of SEC Enforcement Actions,” Hedge Fund Law Report, Vol. 4, No. 44 (Dec. 8, 2011).