The Securities and Exchange Commission has adopted amendments to the Form ADV Part I to capture additional information regarding investment advisers.
Beginning on October 1, 2017, investment advisers filing an initial or amended Form ADV will be required to provide additional information regarding separately managed accounts, aggregated data related to the use of borrowings and derivatives, more detailed information regarding the clients of the adviser, information about the top twenty-five (25) branch offices, information about the CCO, information regarding the adviser’s use of social media and much more. This means that advisers with a fiscal year of December 31st, will need to provide this information during their annual update period which is due by March 31st, 2018. However, any adviser who is required to file an Other than Annual Update on or after October 1st will be required to provide all the additional information. The system will not allow an incomplete Part I to be filed.
Please click here to see a copy of the proposed ADV Part I starting October 1, 2017. As you can see it contains a lot of redlined additions.
Red Oak is here to help you to meet this new regulatory requirement. Let Red Oak help you with your next annual ADV update to help ensure you are compliant with these new requirements.