ADV Annual Updating Amendments are due for most registered investment advisers and exempt reporting advisers within 90 days of the fiscal year end. That sets the filing date for 2016 firmly on March 30th.
In updating the Form ADV, firms should be particularly mindful of changes in these key areas:
- Identifying information, including contact persons;
- Information about the advisory business, including:
- Employee counts;
- Client counts; and
- Regulatory Assets Under Management.
- Private fund reporting;
- Offering memoranda and subscription documents;
- Firm strategies, policies and procedures;
- Conflicts of interest;
- Custody changes; and
- Use of consultants for compliance and cybersecurity.
Firms should especially lean on their brokers, custodians, administrators, legal counsel and compliance consulting firm to accurately and correctly complete the Form ADV Annual Updating Amendment process.