SEC Amends Form ADV And Recordkeeping Rules
by Scott McBride, Scott H. Moss, Esq. and George Danenhauer, Esq.
Published: December, 2016
Submission: December, 2016
The amendments adopted in the final rule are largely consistent with the proposed amendments, but with several modifications to address comments received. Compliance with the amendments adopted in the final rule is generally required on or after October 1, 2017. The amendments are summarized below.
Separately Managed Accounts
Advisers are required to report aggregate information about their separately managed accounts, which the SEC considers to include all advisory accounts other than those that are pooled investment vehicles (i.e., registered investment companies, business development companies, and pooled investment vehicles that are not registered). The specific separate account reporting requirements include amendments to Item 5 of Part 1A and Section 5 of Schedule D of Form ADV requiring aggregate-level information regarding separately managed accounts:
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