Annual updating amendment to form adv

These responses represent the views of the staff of the Division of Investment Management.

They are not a rule, regulation, or statement of the Commission, and the Commission has neither approved nor disapproved this information.

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-4509

The Amendments require increased information concerning SMAs by adding specific questions in Item 5 of Form ADV with respect to (a) the type of asset(s) held by the SMAs; (b) the use of derivatives and borrowing; and (c) the role of custodians. The SEC declined to provide definitions of these terms in Form ADV and instead, permits investment advisers to use their own methodologies in determining appropriate asset categories.

As of February 28, 2017, 2,879 of those firms have filed a Form ADV amendment in 2017.

Thus, at the federal level, close to 75% of firms have still yet to file the required amendment.

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.

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