On May 20, 2015, the Securities and Exchange Commission (the “SEC”) proposed new rules, forms and amendments that would expand the information that registered investment advisers are required to report. The changes are intended to enhance the information available to investors and to permit the SEC to more effectively collect and use information reported by investment advisers.

The SEC proposals would (1) amend Form ADV to require investment advisers to report additional information about separately managed accounts and about the adviser and its business, (2) incorporate a method for multiple private fund adviser entities operating a single advisory business to register using a single Form ADV, (3) effect certain other clarifying and technical amendments to Form ADV, (4) amend the Investment Advisers Act of 1940 (as amended, the “Advisers Act”) books and records rule to require advisers to make and keep additional supporting documentation relating to performance calculations, and (5) effect certain technical amendments to the Advisers Act rules...