SEC Proposes Amendments to Form ADV Regarding Separately Managed Accounts and Umbrella Registrations

On May 20, 2015, the SEC proposed amendments to Form ADV that, if adopted, will require registered investment advisers (but not exempt reporting advisers) to provide additional information regarding any separately managed accounts (“SMAs”) they advise. The proposal would also codify a method for private fund adviser entities operating a single advisory business to register using a single Form ADV (“Umbrella Registration”) and would make certain clarifying, technical and other amendments to Form ADV. The SEC also is proposing amendments to the Investment Advisers Act of 1940 (the “Advisers Act”) recordkeeping rule.

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