From 1 October 2017, all investment advisers completing Form ADV have been required to use a revised version of the form. The two biggest changes impacting foreign registrants are (1) increased disclosure of separately managed accounts for full registrants and (2) additional operational disclosures for both full registrants and reporting advisers.
Registered investment advisers (RIAs) are now required to provide aggregate information about the SMAs managed by them in a separate section. The additional SMA information is not required from the Exempt Reporting Advisers (ERAs). However, there are several other changes that have been introduced that will apply to both RIAs and ERAs including disclosures related to social media, affiliates and private funds. We have published an article which explains the changes in Form ADV that apply to ERAs and can be accessed here.
This year Bovill has expanded its global capabilities by opening an office in United States and has added a dedicated resource in the APAC region to further enrich our US regulatory practice and service clients based in APAC who are RIAs or ERAs. We provide a comprehensive suite of US regulatory services which includes review and drafting of Form ADVs and other regulatory filing assistance.
We can help you navigate the upcoming Form ADV changes and year end US compliance tasks by providing:
- A comprehensive review of your firm’s Form ADV Part 1 and 2
- Assistance amending or redrafting Form ADV Part 2
- Rule 206(4)-7 Annual compliance review
- EDGAR support and filing
We can help navigate your firm’s US compliance needs from our global offices. If you have any questions about these requirements or need any other support please contact Billie-Joe Dixon on email@example.com, Keith Chan on firstname.lastname@example.org or Ross Goffi on email@example.com.