The 10 most significant Form ADV changes
April 4, 2017 12:21 PM
The SEC wants to know more about you — and about how you run your advisory firm. That means increasing scrutiny of how the firm makes its money, uses social media and how it stays compliant with changing regulations and audits its figures.
To that end, the commission's always evolving Form ADV — a rich repository of information about RIAs for regulators, law enforcement bodies, researchers and the public — underwent its most recent revamp in August.
Please scroll through the 10 most significant changes as identified by the compliance outsourcing firm Cipperman Compliance Services. Firms with a Dec. 31 fiscal year have until next year to implement the changes. However, many firms have already begun the process in preparation for the annual update.
To that end, the commission's always evolving Form ADV — a rich repository of information about RIAs for regulators, law enforcement bodies, researchers and the public — underwent its most recent revamp in August.
Please scroll through the 10 most significant changes as identified by the compliance outsourcing firm Cipperman Compliance Services. Firms with a Dec. 31 fiscal year have until next year to implement the changes. However, many firms have already begun the process in preparation for the annual update.
Bloomberg News
1. Analyze your SMAs
Separately Managed Accounts: The new Form ADV requires significant reporting on separately managed account assets including reporting by asset type and related derivative transactions.
Michael Nagle/Bloomberg
2. Don't hide under an umbrella
Umbrella Registration: The new filing rules allow affiliated advisers to use a single Form ADV, but the registrant must complete a detailed schedule for each relying adviser.
Patrick T. Fallon/Bloomberg
3. Break down your social life
Social Media: Every registrant must include websites and social media addresses.
Jason Alden/Bloomberg
4. Up your office listings
Offices: An advisory firm with multiple offices must list its largest 25 offices (used to be 5).
Bloomberg News
5. Name your compliance czar
Outside CCO: If a firm retains a Chief Compliance Officer paid by a third party, the new Form ADV requires the registrant to name the CCO and his/her employer.
6. Break down your assets
Assets Under Management: The new Form ADV requires more detailed reporting of regulatory assets under management by client type.
mediaphotos/Getty Images/iStockphoto
7. Get your head around wraps
Wrap Programs: Registrants must include more detailed information about the wrap programs in which they participate.
Bloomberg News
8. Explain how referrals impact pay
Referral Payments: The new rules require more disclosure about compensation paid, or received for, referrals. That includes amounts paid by, or to, employees.
Bloomberg News
9. ID more bad apples
Bad Actors: The disclosure reporting page, also known as the bad actor disclosure, requires information about all relying advisers.
10. Out your auditor
Auditors: New Form ADV requires information about the auditors to private funds.
