This coming year will have a revamped ADV with some new requirements. A significant new consideration is the challenges that new cryptocurrencies and other digital assets present for investment advisers and their compliance programs. Beyond the considerations for clients and the merits as an asset class, if a particular cryptocurrency or digital asset (such as an ICO, “securities” token or “utility” token) is a security, then trading in such asset by covered persons of an investment adviser are covered under an investment adviser’s personal securities trading policy