As summer recedes and we head into the autumn, investment advisers are in the home stretch of preparations for Form ADV reporting and disclosure changes that become effective October 1, 2017. The amendments, which were adopted in August 2016, require registered investment advisers to provide additional information regarding separately managed accounts and impose new disclosure obligations on private fund advisers that file a single registration for multiple private fund advisers that collectively conduct a single advisory business.
Although the compliance date for the amendments is October 1, 2017, many advisers will first transition to the new Form ADV in connection with their annual updating amendment for fiscal year 2017, which is generally due in March 2018. Set forth in our guide is a summary of the upcoming changes and some checklists to facilitate implementation. Advisers that have not yet considered how the amendments will affect their upcoming annual filing should do so now.
Read our user guide.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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