SEC Form ADV SMA Amendments and Investment Adviser Recordkeeping Rules: Compliance Deadline Quickly Approaching

June 27, 2017

The October 1, 2017 compliance date for the amendments to Form ADV and to rule 204-2 (Recordkeeping Rule), as well as technical amendments to other rules under the Investment Advisers Act of 1940 (Advisers Act) (collectively, Final Rule), is quickly approaching. As a result, advisers registering on Form ADV will be required to report additional information – with a focus on separately managed accounts (SMAs) – that will be made available to the general public. In addition, advisers will be required to comply with certain recordkeeping requirements related to written communications of performance or securities recommendations.

In anticipation of the compliance date, advisers may need to begin collecting and retaining information now and should consider whether any changes should be made to their policies and procedures related to Form ADV reporting and recordkeeping for written communications.

This OnPoint focuses on record retention efforts that may need to take place in anticipation of the compliance date.

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