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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