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Sep 06, 2016

SEC Adopts New Disclosure and Recordkeeping Requirements for Investment Advisers

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In May 2015, we reported on proposals by the Securities and Exchange Commission to expand public disclosures by registered investment advisers (“RIAs”) of various aspects of their separately managed accounts (“SMA”) businesses. The SEC also proposed to (i) expand other information required of RIAs and exempt reporting advisers on their Form ADV filings, (ii) formalize its “umbrella registration” procedures for related investment advisers, (iii) amend certain books and records rules under the Investment Advisers Act of 1940 and (iv) make related technical changes to Form ADV and other Advisers Act rules. Notwithstanding a number of strongly stated industry concerns, the SEC voted on August 25, 2016 to adopt these Form ADV and rule amendments essentially as proposed.

View full memo, SEC Adopts New Disclosure and Recordkeeping Requirements for Investment Advisers

Authors and Contributors

Nathan Greene

Partner

Investment Funds

+1 212 848 4668

+1 212 848 4668

New York

John Adams

Partner

Investment Funds

+44 20 7655 5740

+44 20 7655 5740

London

Lorna Xin Chen

Partner

Investment Funds

+852 2978 8001

+852 2978 8001

Hong Kong

John (Sean) Finley

Partner

Investment Funds

+1 212 848 4346

+1 212 848 4346

New York

Laura Friedrich

Partner

Investment Funds

+1 212 848 7411

+1 212 848 7411

New York

Paul Schreiber

Of Counsel

Investment Funds

+1 212 848 8920

+1 212 848 8920

New York

Thomas Majewski

Counsel

Investment Funds

+1 212 848 7182

+1 212 848 7182

New York