More specifically, the Amendments modify the requirements under Part 1A of Form ADV to require (among other things), (1) additional reporting requirements with respect to separately managed accounts; (2) registration on a single Form ADV of multiple private fund advisers operating as a single advisory business in a “relying adviser” structure (“”); (3) additional disclosures about investment advisers and their businesses; and (4) certain clarifying and technical changes.Additionally, the Amendments include a revision to Rule 204-2 of the Advisers Act (relating to recordkeeping), requiring investment advisers to maintain additional records of performance calculations and performance-related communications.For ERAs, the short-form ADV contains fewer items ( below for ease of reference) so these firms may prefer to file it as soon as their year-end numbers are final to check it off their lists.
For SEC-registered firms with between $25-$100 million in AUM, the fee is $150 and for the SEC-registered firms with less than $25 million in AUM, the fee is $40.
The staff of the Division of Investment Management has prepared the following responses to questions related to Form ADV and expects to update this document from time to time to include responses to additional questions.
As is typical, most investment advisory firms appear to be waiting to file the mandatory annual renewal amendment until closer to the March 31, 2017 deadline.
According to the latest publicly available Securities and Exchange Commission ("SEC") RIA registration data, there are 11,277 SEC-registered RIA firms with a December fiscal year-end initially registered in 2016 or a prior year.
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