News & Analysis as of

Form ADV Reporting Requirements

Adams & Reese

SEC Proposes to Modernize "Small Entity" Definitions for Funds and Advisers

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What you need to do: Identify whether your fund family is at or below ~$10 billion in aggregate net assets and whether your advisory business is under $1 billion regulatory assets under management (“RAUM”); confirm Form N-CEN...more

Mayer Brown Free Writings + Perspectives

SEC Proposes Updates to “Small Entity” Definitions for Funds and Advisers

On January 7, 2026, the Securities and Exchange Commission (“SEC”) proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as “small...more

Seward & Kissel LLP

SEC Delegates Authority to the Director of the Division of Investment Management in Connection with Confidential Information...

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On December 29, 2025, the Securities and Exchange Commission (the “SEC”), through a rule amendment,1 delegated authority to the Director of the Division of Investment Management to authorize the issuance of orders to grant,...more

Foley Hoag LLP

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 8

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As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 8, 2025 in order to cover such fees (with a recommendation from IARD...more

Proskauer - Regulatory & Compliance

SEC Guidance on the Government Shutdown

As of 12:01 am on October 1, 2025, congressionally appropriated funding lapsed for most operations of the United States government. Though the government has shut down, business continues, and market participants that need to...more

Seward & Kissel LLP

Latest Disclosure Trends in the Form ADV Brochure

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Stay ahead of the curve with Seward & Kissel’s analysis of Form ADV Part 2A (“Brochure”) filings from leading SEC-registered investment advisers...more

Troutman Pepper Locke

FUNDamentals: Form N-PX — Institutional Investment Managers Must File, Even if No ‎Proxies Were Voted

Troutman Pepper Locke on

With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers (UPDATED)

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As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Are Entities in Your Private Fund Structure Reportable under FinCEN’s Beneficial Ownership Regulation?

As of January 1, 2024, the Beneficial Ownership Information Reporting Requirements (the “Reporting Rule”) issued by Financial Crimes Enforcement Network (“FinCEN”) to implement Section 6403 of the Corporate Transparency Act...more

Lowenstein Sandler LLP

Slew of Recent SEC Enforcement Actions: Guidance for Registered Investment Advisers

Lowenstein Sandler LLP on

On September 5, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions against five investment advisers for violating Rule 206(4)-2 (the Custody Rule) and Rule 204-1(a) (the ADV Reporting Rule) of the...more

Thompson Coburn LLP

SEC proposes ESG reporting and disclosure requirements for investment advisers

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The U.S. Securities and Exchange Commission (the “SEC”) recently proposed amendments to certain rules and reporting forms under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which would require...more

Robinson & Cole LLP

2018 Investment Adviser Update - When it Comes to Regulatory Environment, It’s “Meet the New Boss, Same as the Old Boss”

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Private equity and hedge fund advisers continue to be subject to an increasing degree of supervision by the Securities and Exchange Commission (SEC) and other governmental agencies and self-regulatory organizations. The...more

Winstead PC

Investment Advisers Regulatory Checklist

Winstead PC on

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...more

Broker-Dealer Compliance + Regulation

Form ADV Amendments: Ready to Go?

As summer recedes and we head into the autumn, investment advisers are in the home stretch of preparations for Form ADV reporting and disclosure changes that become effective October 1, 2017. The amendments, which were...more

Stinson - Corporate & Securities Law Blog

SEC Charges Chief Compliance Officer for Failure to Verify Information

David I. Osunkwo was a principal at Strategic Consulting Advisors, LLC, or SC Consulting. SC Consulting offered compliance consulting and CCO services to two SEC registered investment adviser firms under common control, Aegis...more

Herbert Smith Freehills Kramer

Funds Talk: July 2017 - SEC Updates Form ADV FAQs to Offer Guidance on Complying With Recent Rule Changes

The Securities and Exchange Commission’s (SEC) Division of Investment Management recently modified its “Frequently Asked Questions on Form ADV and IARD,” adding several new topics and updating one existing item....more

Ballard Spahr LLP

Investment Management Update

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Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Bracewell LLP

SEC's New Rule Requires Additional Disclosures on Form ADV

Bracewell LLP on

On August 25, 2016, the SEC adopted Release No. IA-4509 (the “New Rule” or the “amendments”) that amends Form ADV to increase the amount of information that registered investment advisors (“Advisors”) must disclose to the...more

Eversheds Sutherland (US) LLP

SEC Adopts Changes to Form ADV and Books and Records Rules

On August 25, the Securities and Exchange Commission (the SEC) adopted amendments to Form ADV Part 1 that will require SEC-registered investment advisers to provide a significant amount of new information. The SEC adopted...more

BCLP

SEC Adopts Revisions to Form ADV Part 1A and Advisers Act

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The Securities and Exchange Commission (“SEC”) adopted revisions to Part 1A of the Form ADV on August 25, 2016. All investment advisers registered with the SEC under the Investment Advisers Act of 1940, as amended (the...more

Proskauer Rose LLP

SEC Adopts Changes to Form ADV Affecting Advisers to Private Investment Funds

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On August 25, 2016, the U.S. Securities and Exchange Commission (SEC) adopted numerous substantive and technical amendments to Form ADV, Part 1A, which previously had been proposed in a release dated May 20, 2015. Several of...more

Dorsey & Whitney LLP

Form ADV Gets an Overhaul

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On August 25, 2016, the Securities and Exchange Commission (“SEC”) modernized the reporting regime for investment advisers by adopting amendments to the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and...more

Stinson - Corporate & Securities Law Blog

SEC Updates Form ADV

The SEC has adopted final rules requiring investment advisers to provide additional information on Form ADV and other matters. The final rules: - require information about an investment adviser’s separately managed...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Expanding Reporting Requirements for Investment Advisers

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...more

Stinson LLP

SEC Proposes Significant Reporting Requirement Amendments to Form ADV

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On May 20, 2015, the Securities and Exchange Commission (SEC) released several proposals, "Amendments to Form ADV and Investment Advisers Act Rules," that would require investment advisers to provide additional information on...more

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