The anniversary filing of the revamped Form ADV Part 1A, which included material changes to the Part 2A brochure, is thankfully behind us. The “Annual Updating Amendment” was filed by April 1st this year (2013), for the majority of registered SEC1 advisers, Exempt Reporting Advisers, and new private fund advisers. The industry wrestled with the initial interpretation of Form ADV fi ling back in 2011 — and then wrestled with interpretations for the anniversary of the compliance filing date, following the SEC’s revamping of ADV disclosures to include private funds. And now, a year later, what have we all learned from those early days, from the SEC’s very helpful Q&A’s, and from each other?
There still remain some complicated questions – questions the SEC didn’t envision when drafting the revised Form ADV, just as the SEC Rules adopted in 19402 didn’t contemplate private equity firms, exempt reporting advisers, or relying advisers. How the world has changed.
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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.