SEC Adopts Amendments to Form ADV Regarding Separately Managed Accounts and Umbrella Registration and Advisers Act Recordkeeping Rule

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The SEC has adopted final rules to amend Form ADV and the Investment Advisers Act of 1940 (the “Advisers Act”) recordkeeping rule that will (i) require registered investment advisers to provide additional information regarding the separately managed accounts (“SMAs”) they advise, (ii) make certain clarifying, technical and other revisions to Form ADV, (iii) codify the method for multiple private fund adviser entities operating a single advisory business to register using one Form ADV (“Umbrella Registration”) and (iv) make certain revisions to the Advisers Act recordkeeping rule regarding performance information. Advisers will be required to provide responses to the amended Form ADV and comply with the revised recordkeeping rule starting on October 1, 2017. However, the first time most advisers will respond to the revised form will be in connection with their annual Form ADV updates in early 2018. The new requirements regarding SMAs and the recordkeeping rule and the ability to use Umbrella Registration will not apply to exempt reporting advisers.

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