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Recordkeeping Requirements Form ADV

Eversheds Sutherland (US) LLP

SEC proposes sweeping revisions to Advisers Act Custody Rule

On February 15, 2022 the US Securities and Exchange Commission (SEC) proposed sweeping changes to Rule 206(4)-2 (the Custody Rule) under the Investment Advisers Act of 1940 (Advisers Act), which would be redesignated as Rule...more

Morgan Lewis

SEC Proposes New Rule Relating to Outsourcing of Services by Investment Advisers

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The US Securities and Exchange Commission recently proposed a new rule and rule amendments that, if adopted as proposed, would require registered investment advisers to meet certain requirements when outsourcing certain...more

Eversheds Sutherland (US) LLP

SEC proposes service provider oversight requirements for investment advisers

On October 26, 2022, the Securities and Exchange Commission (SEC) proposed new Rule 206(4)-11 under the Investment Advisers Act of 1940 (Advisers Act), which would prohibit SEC-registered investment advisers from outsourcing...more

Cooley LLP

SEC Proposes New Rule and Record-Keeping Requirements for Outsourcing by Registered Investment Advisers

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Engaging service providers and outsourcing various functions is a normal part of running an effective business. From the newest emerging managers to the most established ones, venture capital firms and private fund shops...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Cybersecurity Risk Management Requirements for Investment Advisers and Registered Funds

On Feb. 9, 2022, the Securities and Exchange Commission (SEC or Commission) proposed a suite of new rules and amendments concerning cybersecurity risk management for registered investment advisers (advisers) and registered...more

Miller Canfield

New Investment Adviser Marketing Rules Take Effect May 4, 2021

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On December 22, 2020, the SEC adopted amended Rule 206(4)-1 under the Investment Advisers Act of 1940, updating the rules governing investment adviser marketing ("Marketing Rules"). The new Rule replaces the currently...more

Proskauer Rose LLP

SEC Revises Marketing Rule for Registered Investment Advisers

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On December 22, 2020, the Securities and Exchange Commission (“SEC”) adopted amendments to existing Rule 206(4)-1 (the “Advertising Rule”) and rescinded Rule 206(4)-3 (the “Cash Solicitation Rule”) under the Investment...more

Dechert LLP

SEC Proposes Amendments to the Advertising and Solicitation Rules

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The U.S. Securities and Exchange Commission has proposed amendments to Rule 206(4)-1 – Advertisements by Investment Advisers (Current Advertising Rule) and Rule 206(4)-3 – Cash Payments for Client Solicitations (Current...more

Cadwalader, Wickersham & Taft LLP

SEC Proposes Significant Amendments to Investment Adviser Solicitation Rule

The Securities and Exchange Commission (the “Commission” or the ”SEC”), on November 4, approved the publication of a substantial release (the “Release”) proposing significant amendments to the rules under the Investment...more

Faegre Drinker Biddle & Reath LLP

SEC Proposes Wide-Ranging Changes to Investment Adviser Marketing Rules

On November 4, 2019, the Securities and Exchange Commission (SEC) released a proposed rule amendment (the Marketing Amendment) that would substantially modify SEC Rules 206(4)-1 (the Advertising Rule) and 206(4)-3 (the...more

Vedder Price

SEC Proposes Modernizing Adviser Advertising and Cash Solicitation Rules

Vedder Price on

On November 4, 2019, the U.S. Securities and Exchange Commission (SEC) proposed significant amendments to the rules under the Investment Advisers Act of 1940 (Advisers Act) governing investment adviser advertisements and...more

Morgan Lewis

SEC Amendments to Form ADV and Recordkeeping Rules Go into Effect on October 1

Morgan Lewis on

The amended Form ADV, which goes into effect October 1, 2017, will require investment advisers to expand the information they report on Form ADV about separately managed accounts and other important aspects of their advisory...more

Dechert LLP

SEC Form ADV SMA Amendments and Investment Adviser Recordkeeping Rules: Compliance Deadline Quickly Approaching

Dechert LLP on

The October 1, 2017 compliance date for the amendments to Form ADV and to rule 204-2 (Recordkeeping Rule), as well as technical amendments to other rules under the Investment Advisers Act of 1940 (Advisers Act) (collectively,...more

Blank Rome LLP

Regulatory Update and Recent SEC Enforcement Actions

Blank Rome LLP on

On June 2, 2016, the SEC announced that it hired Christopher R. Hetner, a cybersecurity expert, as the Senior Adviser to the Chair for Cybersecurity Policy. The hire is indicative of the SEC’s focus on cybersecurity measures...more

K&L Gates LLP

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

K&L Gates LLP on

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...more

Stinson LLP

SEC Amendments to Form ADV and Advisers Act Rules Change Investment Adviser Reporting Requirements

Stinson LLP on

Proposals made by the Securities and Exchange Commission (SEC) in 2015 to amend Form ADV and certain rules under the Investment Advisers Act of 1940 (Advisers Act) (SEC Proposes Significant Reporting Requirement Amendments to...more

Cole Schotz

SEC Adopts Changes Impacting Private Fund Advisers

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The SEC’s recently-adopted changes to Form ADV and Rule 204-2 of the Investment Advisers Act of 1940, as amended (the so-called “books and records rule”), raise important considerations for many private fund advisers –...more

Dechert LLP

SEC Amends Form ADV and Investment Adviser Recordkeeping Rules

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC) recently adopted amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule), as well as technical amendments to other rules under the Investment Advisers Act of 1940...more

Katten Muchin Rosenman LLP

Significant Changes to Form ADV and Performance Advertising Rules Adopted

On August 25, the Securities and Exchange Commission (SEC) adopted amendments to Form ADV and to certain rules promulgated under the Investment Adviser Act of 1940, as amended (the "Advisers Act"). These amendments will be...more

A&O Shearman

SEC Adopts New Disclosure and Recordkeeping Requirements for Investment Advisers

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In May 2015, we reported on proposals by the Securities and Exchange Commission to expand public disclosures by registered investment advisers (“RIAs”) of various aspects of their separately managed accounts (“SMA”)...more

Morrison & Foerster LLP

The SEC Adopts Amendments to Form ADV and Recordkeeping Rule: Advisers Now Required to Disclose Information About Separately...

The Securities and Exchange Commission (SEC) recently amended Form ADV to require investment advisers to disclose more information about their separately managed account business, aggregate data related to the use of...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

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Dechert LLP

SEC Proposes to Amend Form ADV and Investment Adviser Recordkeeping Rules

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC or Commission) recently proposed amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule) and other rules under the Investment Advisers Act of 1940, as amended (Advisers...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes Changes to Form ADV 1A Regarding Managed Accounts

The Securities and Exchange Commission (SEC) proposed a new round of changes to its check-the-box registration form for investment advisers, Part 1A of Form ADV (“ADV 1A”), and proposed some minor changes to its recordkeeping...more

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