Tag: Form ADV

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 … Continued

OCIE Now Conducting Exams Off-Site Unless Necessary

On March 23, 2020, the SEC’s Office of Compliance Inspections and Examinations posted an announcement on its website that “in light of health and safety concerns and other circumstances, OCIE has moved to conducting examinations off-site through correspondence, unless it is absolutely necessary to be on-site.” Similarly, over recent weeks, CSS has arranged with clients … Continued

SEC Offers Additional Relief for Advisers Impacted by Coronavirus

The SEC has made several COVID-19 related announcements this week pertaining to investment managers that offer relief from routine regulatory obligations. First, the SEC has issued relief in filing due dates and delivery requirements related to the Coronavirus (COVID-19) and the current market conditions. This will extend the reporting deadline 45 days for Forms ADV, … Continued

SEC Proposes Amendments to Advertising Rules

In a proposal that would mark the first changes since 1961, the SEC has introduced amendments to modify the “Advertisements by Investment Advisers” Rule 206(4)-1 of the Investment Advisers Act. Changes to the rule would allow for testimonials and social media practices beyond that currently allowed, and performance marketing subject to new requirements. Some parts … Continued

SEC Begins Cyber Sweep of Investment Advisers with Focus on Cloud Storage

A sweep of investment advisers is underway by the U.S. Securities and Exchange Commission, which has sent out many letters to firms over the last week requesting information about their use of cloud providers. The move could be part of the SEC’s Phase 3 Cybersecurity Exam Initiative, and is likely related to the April Regulation … Continued

Custody Concerns Continue

You timely filed your Form ADV within 90 days of fiscal year end, but, did you properly answer all the questions related to custody? Not surprisingly, the Form remains confusing for many advisers, as does application of the Custody Rule itself. The SEC has issued guidance, letters to the industry, alerts and FAQs, but things … Continued

Hamilton Lane Announces Successful Form ADV Filing Through Consensus

Leading alternative investment management firm Hamilton Lane recently announced that it successfully filed its Form ADV using Compliance Solutions Strategies’ Consensus platform. “Consensus simplified our Form ADV reporting process,” Hamilton Lane Chief Compliance Officer Fred Shaw said in a press release marking the announcement. “We leveraged the platform’s automated data upload functionality to report efficiently … Continued

What Should Fund COOs Worry About?

Given the dramatic impending changes in regulatory reporting requirements for asset management firms, their chief operating officers, administrators and compliance officials have pretty “full plates” these days. There is no shortage of reporting issues that hedge, mutual, and exchange-traded funds must address, including more extensive requirements arising from the SEC’s modernization drive, such as forms … Continued


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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.

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