SEC Amendments Require Additional Form ADV Disclosures
- exchange-traded equity securities
- non-exchange traded equity securities
- U.S. government bonds
- U.S. state and local bonds
- sovereign bonds
- corporate bonds – investment grade; corporate bonds – non-investment grade
- securities issued by registered investment companies and business development companies
- securities issued by other pooled investment vehicles
- cash and cash equivalents
Further, RIAs with at least $10 billion in total regulatory assets under management in SMAs must disclose this information both at mid-year and at year-end. SMAs must disclose this information only as of year-end.
The Umbrella Registration Procedures
- The filing RIA must maintain its principal office and have a place of business in the United States
- The filing RIA and relying RIAs must advise only private funds and SMAs whose investors are qualified clients that are otherwise eligible to invest in the RIAs’ private funds. The accounts’ investment objectives and strategies must be substantially similar or otherwise related to the RIA private funds
- The advisers must operate under a single code of ethics and single set of written compliance policies and procedures administered by a single compliance officer.
- Each of the relying RIAs and its employees must be subject to the supervision and control of the filing RIA and
- The filing RIA and each relying RIA must be subject to the Investment Advisers Act and examination by the SEC.
Social Media Account Disclosures
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