The SEC today adopted amendments to Form ADV. Under the revised rule, advisers will be required to provide:
- More detailed information about separately-managed accounts, including types of assets held, use of derivatives and borrowings
- Assets under management in wrap fee programs
- Information about adviser social media accounts
- Contact information for an adviser’s top 25 office locations (rather than top 5 locations)
- Details on compensation received by the chief compliance officer from other employers (other than ’40 Act funds)
- More precise information about number of clients and assets under management
- Information on “parallel managed accounts” that are managed similarly to a mutual fund
In addition, the changes codify umbrella registration for private funds that operate through multiple legal entities.
At the same time, the SEC made amendments to adviser recordkeeping requirements in Rule 204-2. In future, advisers must retain:
- Materials related to the calculation of performance information distributed to any person (not just to 10 people or more)
- All written communications related to performance, both sent and received