SEC Adopts Rules To Enhance Adviser Reporting

Recently enacted SEC rules have imposed several amendments to Form ADV that advisers should be aware of, and which will apply to all Form ADVs filed after September 31, 2017 (for most advisers with a December 31-year end, the enhanced reporting will first apply to their annual amendment due March 2018). The revised Form ADV will require substantial additional disclosures with regard to separately managed accounts ("SMAs"), provide for a method of umbrella registration for private fund entities operating a single advisory business, and implement other technical amendments to current items and instructions. In addition, the update imposes new requirements under Rule 204-2, commonly known as the "books and records rule."