The new ADV reporting requirements go into effect October 1, 2017. Under the revised Form ADV, advisers will:
- require investment advisers to disclose additional information about their separately management account (“SMA”) business;
- require investment advisers to report specific information on general business operations, including compliance operations;
- better facilitate the filing of an “umbrella registration” by private fund investment advisers; and
- tighten recordkeeping obligations under Advisers Act Rule 204-2.
WHAT DOES THIS MEAN FOR ME?
Initial Form ADVs and amendments to existing Form ADVs submitted on or after October 1, 2017 will be required to report information requested by the revised form. Amendments to the books and records rule will also take effect on October 1, 2017.
Advisers should review their recordkeeping procedures and the information they will need to report in Part 1A of their Form ADV. Please contact Fairview® with any questions or concerns regarding compliance with the new rules. Fairview® will assist with the revision and implementation of the adviser’s policies and procedures as necessary.