Under the Investment Advisers Act of 1940 (the “Advisers Act”), an investment adviser that manages $25 million or more in client assets must register with the Securities and Exchange Commission (“SEC”) by filing a Form ADV with the SEC. Once registered, advisers are required under Rule 204-3 of the Advisers Act to deliver to all current advisory clients and all prospective clients thereafter a brochure in which the advisers disclose certain information required by Part 2 of Form ADV (“Part 2”).
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