SEC Extends Form ADV & Form PF Relief, Modifies Conditions

On March 25, 2020, the SEC issued a new Order extending and relaxing some of the conditions pertaining to the available relief for filing and delivering Form ADV amendments and for filing Form PF.  Under the new Order, which replaces the March 13 Order, the relief is extended to applicable filing and delivery obligations on or prior to June 30, 2020.

In the replacement Order, the SEC eliminated requirements that advisers inform the SEC why an adviser is unable to meet a deadline and to provide an estimated date of filing or delivery completion. The SEC maintained requirements that the relief applies only under the following conditions:

  • the adviser is impacted by COVID-19 and “unable to meet a filing deadline or delivery requirement due to circumstances related to current or potential effects of COVID-19”, and
  • the adviser “promptly notifies the Commission staff via email at (or at pertaining to Form PF filings) and discloses on its public website (or if it does not have a public website, promptly notifies its clients and/or private fund investors) that it is relying on this Order, and
  • the adviser files Form ADV or Form PF and makes applicable deliveries “as soon as practicable, but not later than 45 days after the original due date for filing or delivery.”

The relief applies to registered investment advisers and exempt reporting advisers.

Because the relief applies to amendments to Form ADV, it does not impact the June 30, 2020 Form CRS filing deadline.

If you need help with your filings, reach out and contact us.

Subscribe to CSS Blog

CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.

Latest Content

From One CCO to Another: Don’t Lie to the SEC

Every once in a while, I think it’s important to get back to the basics. Since the adoption of the compliance rules in 2004, the Securities and Exchange Commission staff has repeatedly stated that the intent of the rules were not to hunt CCOs. Great pains have been made to enlist CCOs support in ensuring … Continued

BME Partners with CSS to Strengthen its Regulatory Service Suite

BME to offer financial services firms in Spain and Portugal a multi-regulation reporting platform Partnership brings a unique combination of local market presence and global coverage BME has partnered with Compliance Solutions Strategies (CSS), a leading RegTech platform provider, to offer a global regulatory reporting solution in Spain and Portugal. The combination of BME’s local … Continued

Compliance Solutions Strategies Acquires AMFINE

Combination Creates First Fully End-To-End Compliance Reporting Platform NEW YORK, September 10, 2020 – Compliance Solutions Strategies (“CSS”), a leading RegTech platform providing technology-driven solutions which enable financial services firms to meet mandatory regulatory compliance requirements, today announced the acquisition of AMFINE (“AMFINE”), a provider of SaaS-based regulatory reporting services to European asset managers, asset … Continued