New Requirements for ADV Updates Starting October 1, 2017.
The Securities and Exchange Commission (the “SEC”) requires SEC-registered investment advisers and exempt reporting advisers to annually update information on Form ADV. Beginning October 1, any initial filing of or amendment to Form ADV will need to be revised to include
- any additional CRD numbers;
- a list of the 25 largest offices in terms of numbers of employees as of the end of the most recent fiscal year;
- the total number of offices that you conduct investment advisory business at;
- links to your websites AND all accounts on publicly available social media (Twitter, Facebook, LinkedIn, etc.);
- the name of your outsourced CCO;
- the number of clients who have no regulatory AUM but provided investment advisory services to;
- the amount of regulatory AUM attributable to each client type;
- the number of clients for each client type;
- if you participate in a wrap fee program, the breakdown of regulatory AUM based on your role as sponsor, portfolio manager and both to the same program;
- the percentage of regulatory AUM attributable to investments in derivatives, registered investment companies, business development companies and pooled investment vehicles;
- the percentage of regulatory AUM attributable to different asset classes;
- use of borrowings and derivatives in separately managed accounts; and
- new Schedule R is you are a relying adviser.
Need help with your initial, annual amendment or other-than-annual amendment filing? Need to update your brochure? Call us today so that we can ensure your filings comply with the changes to Form ADV come October 1.