SEC Adopts Amendments To Form ADV And Recordkeeping Rule

On August 25, 2016, the Securities and Exchange Commission (the "SEC") adopted rules, proposed in May 2015,¹ to modernize and enhance the disclosure requirements promulgated under the Investment Adviser Act of 1940, as amended (the "Advisers Act") and to amend Form ADV (collectively, the "Amendments"). The Amendments are intended to improve the quality of information that clients and the SEC receive, fill data gaps that the SEC has identified and facilitate the SEC's risk monitoring initiatives. More specifically, the Amendments modify the requirements under Part 1A of Form ADV to require (among other things), (1) additional reporting requirements with respect to separately managed accounts; (2) registration on a single Form ADV of multiple private fund advisers operating as a single advisory business in a "relying adviser" structure ("Umbrella Registration"); (3) additional disclosures about investment advisers and their businesses; and (4) certain clarifying and