According to the Investment Adviser Association (IAA), the U.S. Securities and Exchange Commission (SEC) recently sent a letter to IAA Executive Director David Tittsworth. The letter, signed by SEC Chairman Christopher Cox, stated that the “tentative schedule for consideration of final amendments to Form ADV, Part 2 is early December 2008.” The letter went on to state the SEC will be considering the approximately 80 comment letters it received. The letter did not give an indication of when the new Form ADV Part 2 rule would be passed. However, the letter is a clear indication that the new Form ADV, Part 2 is still on the SEC’s short-term agenda.
As we have previously discussed, the SEC originally proposed material changes to the disclosure and format requirements of the Form ADV Part 2 for a registered investment adviser in April 2000. That proposal was never adopted and in March of this year the issue was re-proposed. If the SEC adopts the proposed new Form ADV Part 2 in whole or part, it undoubtedly will take a significant amount of effort by a registered investment adviser over relatively short time period to meet the proposed requirements. However, a registered investment adviser can begin preparing for this possible regulatory change by taking the time now to more fully understand the likely changes and impact of a new Form ADV Part 2. RIA Compliance Consultants encourages registered investment advisor firms to read the proposed rule, particularly the new Form ADV Part 2 instructions. You can view the proposed rule by clicking here. The proposed instructions begin on page 123.
Take the opportunity to better understand the details of the SEC’s proposed new Form ADV Part 2 by attending our complimentary webinar, Understanding the SEC’s Proposed New Form ADV Part 2, on Wednesday, November 19, 2008 from 12:00 p.m. to 1:00 p.m. CST. Please click on the link below if would you like to attend this free webinar. For more information about this webinar, you may also call Annie Dilocker at 877-345-4034.
Posted by Bryan Hill
Labels: ADV Part 2