By now, many have heard about the coming changes to Form ADV which will be effective October 1, 2017. These changes can be largely grouped into three categories:
- Separately Managed Accounts: Firms will be required to provide additional information about their SMA businesses, including assets under management, borrowings and derivatives, number of clients and types of assets held
- Additional Identifying Information: Firms will also be required to include additional identifying information about their businesses, which is either new information (e.g. addresses of all company social media accounts) or more specific answers to existing questions (e.g. stating exact # of clients or AUM where it used to be a range)
- Umbrella Registration: Private fund adviser entities operating a single advisory business who meet certain conditions will be able to register using a single form ADV as part of an “umbrella registration”
In addition to the above, the final rule, which was enacted in October 2016, included changes to the Investment Advisers Act Books and Records Rule requirements. Subsequently-released technical amendments to Form ADV were also issued in May 2017 to reflect the recent changes to Wyoming’s state registration protocol.
The way we’re thinking about these changes are – they’re material, but manageable. We don’t think they should be a huge burden on most firms, but they do require close attention. For that reason, we’re hosting a ComplianceCast on the topic on Thursday, July 20 to talk through the changes in more detail.
In addition, on August 1, we’ll be releasing our free Ascendant Form ADV Toolkit, which will be hosted on our proprietary technology tool, Ascendant Compliance Manager (ACM). The toolkit will have valuable content like templates, checklists of the new information required and commentary from our consulting team to make this process as painless as possible – whether you’re filing your firm’s Form ADV for the first time or the 20th.
*Note if you are an existing client on ACM, you will automatically have access to the toolkit and do not need to register to receive a copy.