ADV Part 2 Deadline Looms: You Have Two Days; We Have 191 Examples
For most filers of Form ADV, March 31, 2011 – this Thursday(!) — is the deadline for the submission of a Part 2A Brochure under new SEC guidelines adopted last year. (The deadline for the Brochure Supplement, Part 2B, has been extended by four months.) As the SEC clarifies in its March 18 “Staff Responses to Questions About Part 2 of Form ADV,” “Each adviser currently registered with the Commission whose fiscal year ends on or after December 31, 2010 must include in its next annual updating amendment to its Form ADV a new brochure (Rule 204-1(c)).”
The adopting release issued last July offers more detail on just what is expected in the new brochure. But of course there is no substitute for precedent. That’s great — if you know how to find that precedent. Only problem is, for many advisers and their counsel, concrete examples of newly submitted ADV brochures are not easy to come by. There is really no way of extracting from the SEC’s IARD database which registrations are new, which include Part 2 brochures, and which of those brochures is itself new (in many cases the registration is from 2011 but the brochure is an older version.)
But as we wrote in this blog last week, subscribers to Knowledge Mosaic can access a spreadsheet that contains precisely the information you need. We currently archive 191 examples of newly updated Part 2 brochures. Visit our Form ADV search page and click on the link.
But if you’re subject to that deadline, better do it soon!