Annual updating amendment to form adv
A copy of the Form ADV and the General Instructions can be found on the SEC website at FINRA provides information about the IARD and the electronic filing process on the IARD website at or by calling 240-386-4848.Some firms also take this opportunity to review their compliance program but given this update requirement and the audit deadline for pooled investment vehicles, the annual compliance review will often be pushed back until later in the year.While we are quickly coming up to March 31, there is still plenty of time to complete the update and private fund managers should reach out to us if they would like our assistance preparing the amendment for this year. A fund manager’s RAUM may be higher than its normally reported AUM because it includes: RAUM should be calculated based on the current market value of the assets as determined within 90 days prior to the date of filing the Form ADV.For private funds, the SEC has stated that a manager may rely on the gross assets as reflected on the fund’s balance sheet, and the manager may assess the value of financial instruments under the applicable accounting standards, which is GAAP in this industry.The process generally will entail a review of the current Form ADV, and Form ADV Part 2 if applicable, to make sure that all information is up to date and accurate.In general, once the review process has begun, the update can be completed in a few days depending on the complexity of firm’s operations and the capacity of the updater to make changes in the system.
There are also changes to certain instructions and the definitions of terms found in the General Instructions to Form ADV (the "General Instructions"). These changes will affect all Massachusetts-registered investment advisers. All amendments will continue to be made electronically using the IARD system (see below). To whom must I deliver Part 2A (Brochure) and 2B (Brochure Supplements)?
That’s the effective date for the new Form ADV (Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers).
The new form reflects numerous changes adopted by the Securities and Exchange Commission (“SEC”) on August 25, 2016 to improve the quality of the information collected on the form and to facilitate risk-monitoring objectives.
Generally, RAUM should include the securities portfolios for which a manager provides continuous and regular supervisory or management services as of the date of filing or update of the Form ADV.
Unlike AUM, the RAUM calculation requires managers to report assets managed without the deduction of any outstanding indebtedness or other accrued but unpaid liabilities (including accrued fees or expenses) that remain in a client’s account.