Form ADV Reporting and Disclosure Amendments: Are You Ready for What Lies Ahead?
Pursuant to the Form ADV reporting and disclosure amendments adopted last 2016, investment advisers are now held to submit new requirements in their upcoming registrations. The new rules, which included three key changes, specifically require investment advisers with additional information on Part 1A of Form ADV regarding their separately managed accounts (SMAs) and advisory business. Additionally, new disclosure obligations on related private fund advisers with a single advisory business (umbrella registrations) are also imposed.
With reporting and disclosure changes dawning for future registrations, it is imperative that investment advisers have a firm transition plan as early as now. Efficiently facilitating these new requirements can be of big help in such implementation.
In this LIVE Webcast, a panel of key thought leaders organized by The Knowledge Group will provide an overview of the new Form ADV reporting and disclosure requirements to help you understand its critical elements and the changes it will set forth. Speakers will also offer best practices in developing an efficient transition plan to facilitate implementation.
Key topics include:
- 2016 Form ADV Amendments
- Key Changes:
- Separately Managed Accounts
- Advisory Business
- Umbrella Registration
- Additional Disclosure Amendments
- Transition Guide
- What Lies Ahead
Katten Muchin Rosenman LLP
- Item 1.I Disclosure About Web and Social Media Sites
- Item 5.D Revisions
- Item 9 Custody Issues in Light of SEC Staff 2017 SLOA Guidance
Willkie Farr & Gallagher LLP
- Umbrella Registration – The amendments are intended to codify the SEC staff’s guidance from the 2012 ABA No-Action Letter.
- Address the umbrella registration conditions.
- Indicia of a “single advisory business.”
- Exclusions from umbrella registration: (1) exempt reporting advisers and (2) filing advisers based outside of the United States.
- New Schedule R
- Item 5 revisions: Item 5.C. (Non-RAUM Assets), Item 5.F. (Non-U.S. Clients), Section 5.G. of Schedule D (RAUM for all Parallel Managed Accounts related to a registered investment company or BDC), Item 5.I. and Section 5.I(2) of Schedule D (wrap fee programs), and Item 5.J. (Client asset computations). Section 7.A. and 7.B.(1)’s new questions requiring the reporting of CIK numbers and PCAOB numbers, as well as a new question related to private funds that rely on Section 3(c)(1).
Richards Kibbe & Orbe LLP
- Introduction/overview of amendments (SEC goals; industry initial response; key implications; timing)
- Item 5.K. (SMA Asset Categories; Borrowing/Derivatives; Custodians)
- I am also happy to do all or part of the other Item 1 changes (Items 1.D. & 1.E. (ID numbers); 1.F. (Offices); 1.J. (Outsourced CCO); 1.O. (Balance Sheet Assets)) and/or the books and records rule changes
Who Should Attend:
- Finance & Related Lawyers
- Corporate Lawyers
- Business Lawyers
- Securities Lawyers
- Investment Advisers
- In-House Counsel
- Compliance Officers
- Other Related and Interested Professionals
David Dickstein, a partner in Katten’s Financial Services practice, represents broker-dealers, investment advisers, investment companies and hedge funds in connection with a variety of regulatory, compliance and operational matters. David regularly counsels investment advisers on registration and regulatory matters, such as the need for registration, conflict of interest disclosures, soft dollars and best execution, firm advertising and marketing, federal and state pay-to-play matters, trade allocations and personal trading. He also advises broker-dealers on registration and ongoing compliance matters, mutual fund supermarkets on mutual fund distribution issues and brokerage and advisory firms on structuring and offering wrap fee programs and other financial products. In addition, David provides assistance in responding to Securities and Exchange Commission (SEC) investigations and examinations and in conducting compliance audits and regulatory reviews.
David Dickstein, a partner in Katten’s Financial Services practice, represents broker-dealers, investment advisers, investment companies and hedge funds in connection …
Anne Choe is a senior associate in the Asset Management Group of Willkie Farr & Gallagher LLP in Washington, DC. Her practice covers a wide range of securities regulation, and she advises mutual funds, exchange-traded funds (ETFs), hedge funds, private equity funds, business development companies, and family offices. She focuses on counseling mutual fund and private fund investment advisers on a variety of regulatory compliance matters and compliance filings, including counseling clients on mock SEC examinations. Anne has represented investment advisers in SEC examination and enforcement matters. She has significant experience advising on the creation and operation of registered open-end investment companies and ETFs. She also has transactional experience involving funds and their advisers, including merger and acquisition transactions.
Anne Choe is a senior associate in the Asset Management Group of Willkie Farr & Gallagher LLP in Washington, DC. …
Kimberly M. Versace advises investment advisers, private funds and other financial institutions on a wide range of investment management issues, with a particular focus on securities regulatory and compliance matters. She counsels investment firms in connection with the development of comprehensive compliance programs to address regulatory obligations imposed by the Investment Advisers Act, the Investment Company Act and other securities laws and regulations. She also provides ongoing advice on a wide variety of regulatory compliance matters, including with respect to SEC registration, disclosure requirements, insider trading rules, conflicts of interest, portfolio management controls and compliance with anti-corruption laws and rules.
Kimberly M. Versace advises investment advisers, private funds and other financial institutions on a wide range of investment management issues, …
Print and review course materials
Method of Presentation:
Experience in SEC reporting and disclosure laws
NY Category of CLE Credit:
Areas of Professional Practice
Unlock All The Knowledge and Credit You Need
Leading Provider of Online Continuing Education
It's As Easy as 1, 2, 3
Get Your 1-Year All Access Pass For Only $199
About Katten Muchin Rosenman LLP
Katten Muchin Rosenman LLP is a full-service law firm with more than 600 attorneys in locations across the United States and in London and Shanghai. Clients seeking sophisticated, high-value legal services turn to Katten for counsel locally, nationally and internationally. The firm’s core areas of practice include
corporate, financial services, insolvency and restructuring, litigation, real estate, environmental, commercial finance, intellectual property, structured finance and securitization, and trusts and
estates. Katten represents public and private companies in numerous industries, including a third of
the Fortune 100, as well as a number of government and nonprofit organizations and individuals. Katten’s leading practices and attorneys have been recognized in Chambers & Partners guides, Best Lawyers in America®, U.S. News – Best Lawyers® “Best Law Firms” and The Legal 500, among others.
About Willkie Farr & Gallagher LLP
Willkie is an elite international law firm of approximately 700 lawyers located in nine offices in six countries. For more than 125 years, Willkie has represented companies across a wide spectrum of businesses and industries, most notably financial services. The firm’s preeminent Asset Management Group provides legal services to a wide array of clients, including privately owned investment advisers, publicly traded asset management firms, broker dealers, insurance companies and banks. Willkie regularly advises asset managers on subjects ranging from operations, to fund formations, to compliance and regulation. The firm provides insight and knowledge into the legal needs of sponsors of public and private funds alike, allowing us to bring a practical, efficient approach to analyzing issues and solving problems. The group is Chambers rated and was named “Investment Funds Firm of the Year” at the 2017 and 2014 Chambers USA Awards for Excellence
About Richards Kibbe & Orbe LLP
RK&O is an elite boutique law firm focused on the financial sector. For more than 25 years, we have represented financial firms in transactions, compliance and litigation, and have consistently been at the forefront of emerging legal issues and investment activities. The sophistication and intensity that have made RK&O a leader in complex financial transactions and compliance issues have also driven our success in representing institutional clients, funds and individuals confronting government investigations, securities law violations and complex business disputes.
RK&O conducts a highly collaborative practice through approximately 65 lawyers based in New York, Washington, D.C. and London. With a long track record of achieving positive outcomes for clients, RK&O attorneys are recognized as being among the most qualified legal practitioners in the financial services sector, both in the U.S. and around the globe.