This post is based on a Mayer Brown LLP publication by Stephanie M. Monaco, Amy Ward Pershkow, Leslie S. Cruz, and Peter M. McCamman.
The compliance date is fast approaching for the US Securities and Exchange Commission’s (“SEC”) recently adopted amendments to Part 1A of Form ADV. Initial or amended Form ADVs filed on or after October 1, 2017 (with limited exception, as discussed below) must comply with the amendments. The Part 1A amendments require advisers to provide additional information about their business, including information about their separately managed accounts (“SMAs”), social media activity, branch offices, source of chief compliance officer (“CCO”) compensation, and participation in wrap fee programs. The amendments also codify the “relying adviser” method by which private fund advisers operating as a single advisory business can register using a single Form ADV, referred to as “umbrella” registration.