February 2015
Rule 204-1[1] of the Securities and Exchange Commission (“SEC”), requires registered investment advisers to file an “annual updating amendment” to the firm’s Form ADV Part 1 and 2A (also known as the “Brochure”) within 90 days after the firm’s fiscal year end (most firms fiscal year ends on December 31st). This amendment reaffirms the information previously filed and updates any other sections for which information may be outdated. This Risk Management Update will help highlight and clarify the definitions of a few parts of the Form ADV that can cause some firms confusion.
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