RIA firms with a fiscal calendar ending on December 31st have until March 31st to file their updated ADVs with the SEC.
In addition, following the SECs new requirements (adopted last summer), there are 8 changes required on the Form ADV for firms filing after October 1. The purpose of the new data is to assist the SEC with its focus to examine more firms, more often that present the greatest risks.
The following is a review of the changes:
- Firms need to provide a list of their 25 largest branch offices (based on employee numbers). This is an increase from the previous 5.
- Advisers need to provide the address for every social media page where they control content. The SEC will be looking for consistency of message.
- Advisers need to report whether their CCO is compensated by an entity other than the adviser or related party.
- Large firms will need to be more precise when reporting assets above $1 billion.
- Advisers will include how many actual clients (not ranges) they have among different categories and how much each category has in AUM.
- Advisers to private fund whose entities operate as one will be able to file an umbrella registration.
- Advisers will have to get more specific about their separately managed accounts (type of assets, use of derivatives and borrowing).
- Advisers who change answers about custody will need to report new responses on all ADVs filed after October 1.