Taking the Plunge: Who will be the first to submit an ADV under the new requirements?
New Form ADV requirements include a Part 2 Brochure in “plain English” (Release No. IA-3129). The rule is presently in effect for new registrants, and will go into effect on March 31st for registrants who already have an ADV on file with the SEC. Take a look at these memos for more details on the new rules and requirements:
- SEC Extends The Compliance Date For New Part 2B of Form ADV Willkie Farr & Gallagher
- The Changing Face of Regulation: Significant Changes Impacting Investment Advisers K&L Gates
- New Part 2 Form ADV; Now It’s All in the ‘Plain English’ Detail Pepper Hamilton
- SEC Adopts Amendments to Form ADV Part 2 Dechert
Blog readers already know how to search for ADVs on knowledgemosaic; you may also know that you can’t search by date submitted or date updated, due to the complexity of the way these documents are submitted. Unlike other SEC filings, Form ADV is submitted through the IARD rather than the EDGAR filing system, and it is not submitted on a regular basis like quarterly or annual reports. Instead, a copy is kept on file with the SEC and updated as needed. What we call “execution pages” usually indicate when the most recent update took place, but not always, and perhaps not consistently (we knew it wouldn’t be that simple!).