SEC Adopts Rules for Reporting Separately Managed Accounts on Form ADV and Revised Recordkeeping Rules


Amendments to Form ADV -

Information Regarding Separately Managed Accounts -

The SEC’s final amendments to Part 1A of Form ADV include items intended to collect more information about each adviser’s SMAs. The amendments are intended to help the SEC make risk assessments with respect to SMAs and their investment advisers. The SEC defines a “separately managed account” as an advisory account that is not a pooled investment vehicle (i.e., a registered investment company, business development company or private fund[2]). Under the final amendments, Item 5.K.(1) was added to Item 5 of Part 1A, asking advisers if they have regulatory assets under management (“RAUM”) attributable to SMAs. If so, the adviser is required to complete additional questions in Item 5.K. of Part 1A and accompanying disclosure in Schedule D.

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