Annual updating amendment to form adv
If an ERA no longer qualifies for the private fund adviser exemption due to an increase in its private fund Regulatory Assets Under Management, the adviser must apply for registration with the SEC within 90 days after filing the annual updating amendment.The adviser may continue to act as a private fund adviser during this transition period provided that it has previously complied with all of its reporting obligations as an ERA. Advisers and ERAs having a December 31 fiscal year end are obligated to file their annual updating amendment by March 31, 2017. Baker Mc Kenzie can assist you in filing this year’s annual update to your Form ADV.
According to the latest publicly available Securities and Exchange Commission ("SEC") RIA registration data, there are 11,277 SEC-registered RIA firms with a December fiscal year-end initially registered in 2016 or a prior year.If these were not amended during the year, they should be reflected on the annual amendment.Part 1A (all firms): The above require amendment if the information provided becomes inaccurate in any way; the below require amendment only if information becomes materially inaccurate.Paper versions of current Form ADV Part 1A, Part 1B, and Part 2, General Instructions to Form ADV, Glossary, Instructions for Part 1A of Form ADV, and General Instructions for Part 2A of Form ADV can be found here: https://gov/about/forms/A staff summary of changes adopted to Form ADV Part 1A that will be implemented on October 1, 2017 is available here: https://gov/rules/final/2016/ia-4509Contact the Baker Mc Kenzie attorney with whom you work or one of the contacts in the left column for additional details.
Annual Updating Amendments to Form ADV are due within 90 days of an adviser’s fiscal year end.
For ERAs, the short-form ADV contains fewer items ( below for ease of reference) so these firms may prefer to file it as soon as their year-end numbers are final to check it off their lists.
Where applicable, the ADV items listed below include the corresponding Schedules A-D. Other Items Requiring Prompt Amendments The following are items that are amended promptly as they occur, rather than waiting for the annual filing.
Note that some of these items have a corresponding section of Schedule D.
Part 2: If any information in the Firm Brochure and/or supplement(s) become materially inaccurate, an Other-than-Annual amendment is required.
As of February 28, 2017, 2,879 of those firms have filed a Form ADV amendment in 2017.