Introduction -
Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals.
Developments -
•Changes to Form ADV. The Securities and Exchange Commission (SEC) amended Part 1A of Form ADV effective as of October 1, 2017, to (i) codify the SEC staff’s (the “Staff”) guidance permitting “relying advisers” to use the filings of related “filing advisers” to become registered with the SEC; (ii) require additional reporting regarding separately managed accounts; and (iii) require additional information regarding the adviser, including use of social media and outsourced chief compliance officers...
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