SEC Proposes Amendments To Form ADV And Performance Information Recordkeeping Requirements

On May 20, 2015, the Securities and Exchange Commission (SEC) released proposed amendments to Form ADV and Rule 204-2 under the Investment Advisers Act of 1940 (Advisers Act).[1]  The proposed amendments, if adopted, would require investment advisers to provide additional information on Form ADV and expand their obligation to maintain records of performance calculations and performance-related communications.

Proposed Amendments to Form ADV

According to the SEC's press release, the proposed amendments to Form ADV seek to gather additional information for the SEC and the public to better understand the risk profile of individual investment advisers and the industry overall. The proposed amendments would require an investment adviser to report additional information on its separately managed account clients and other facets of its advisory business. Moreover, the proposed amendments would codify the umbrella registration process for private fund adviser entities