While it took years for Form ADV to be revised,1 an investment adviser registered, or required to be registered, under the Investment Advisers Act of 1940 ("Advisers Act") does not have even one year to comply with the amendments to Form ADV, and certain related Advisers Act rules, that were promulgated by the U.S. Securities and Exchange Commission ("SEC") on July 28, 2010. In light of this timing, an investment adviser planning on registering, or one that is registered and has in the past begun its Form ADV updating process in the first calendar quarter, would be well-served to begin thinking now about the requirements under amended Form ADV.2
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