As discussed in this previous Compliance Corner post, the SEC recently amended Form ADV Part 1A to incorporate numerous changes to the registration, reporting, and recordkeeping requirements imposed by the Dodd-Frank Act. The IARD system has now been updated to reflect the Form ADV Part 1A revisions and as a result, firms filing new applications for registration or amendments to existing applications will be required to provide significant additional information required by the new Form. The Form ADV Instructions and Glossary of Terms has also been revised to reflect the new requirements and definitions used throughout Form ADV.
As amended, Form ADV (now officially named the “Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers”) requires firms to provide more detailed information about private funds they advise, information about the number and types of clients of the adviser, whether the firm holds itself out as specializing in certain types of investments, and more specific information about the number of employees of the firm that are investment adviser representatives, licensed insurance agents, registered representatives of a broker-dealer, or perform advisory functions. In addition, firms must provide more details pertaining to the adviser’s other business activities and financial industry affiliations. The SEC has provided a redlined version of Form ADV Part 1A showing the substantive changes made from the prior version.
For additional information or for assistance with the new requirements of Form ADV, please contact Zac Rosenberg, Compliance Consultant by email at firstname.lastname@example.org or by phone at (619) 278-0020.