On May 20th, the Securities and Exchange Commission (the “SEC”) proposed amendments to Form ADV, Part 1A and the related instructions and glossary (collectively, “Form ADV”). Jesse Kanach and Shawn Durrani of Perkins Coie’s Washington D.C. office have prepared the attached documents, which show what Form ADV would look like, if the SEC adopted all of these recently proposed changes.
View the proposed changes to the Glossary Instructions Form ADV.
View the proposed changes to Part 1A of Form ADV.
In summary, the changes are being proposed in order to:
1) Fill certain data gaps and enhance current reporting requirements in respect of “separately managed accounts,” including pension plans, endowments, foundations, other institutional clients and retail clients. Advisers would be required to provide information on regulatory assets under management, investments and use of derivatives and borrowings. This aspect of the proposal, which will be analyzed under a separate posting, closely mirrors similar requirements under existing Form PF.
Continue Reading What Form ADV would look like, if the SEC adopted all of its recently proposed changes