As a result of the efforts of the Securities Industry and Financial Markets Association (SIFMA), the Securities and Exchange Commission (SEC) has extended the compliance date out four months with respect to the delivery of the brochure supplement set forth in Part 2B of Form ADV, and for certain rule provisions that relate to the delivery of brochure supplements.
Under the extension, all investment advisers registered with the SEC as of December 31, 2010, and having a fiscal year ending on December 31, 2010 through April 30, 2011, will have until July 31, 2011, to begin delivering brochure supplements to new and prospective clients and will have until September 30, 2011 to deliver brochure supplements to existing clients. The compliance dates for delivering brochure supplements for existing registered investment advisers with fiscal years ending after April 30, 2011 remain unchanged.
With respect to newly registered investment advisers filing their applications for registration from January 1, 2011 through April 30, 2011, they have until May 1, 2011 to begin delivering brochure supplements to new and prospective clients and will have until July 1, 2011 to deliver brochure supplements to existing clients. The compliance dates for delivering brochure supplements for newly-registered investment advisers filing applications for registration after April 30, 2011 remain unchanged.
Courtesy of The LeGaye Law Firm
Michael Schaps, Co-Author
Daniel E. LeGaye, Co-Author
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