SEC Proposes Amendments To Form ADV And Recordkeeping Rule

In late May, the Securities and Exchange Commission (the "SEC") proposed rules that would amend portions of Form ADV and rules promulgated under the Investment Adviser Act of 1940 (the "Advisers Act"). The proposed amendments are intended to improve the quality of information that investors and the SEC receive, fill data gaps that the SEC has identified and facilitate the SEC's risk monitoring initiatives. The proposed amendments relate to Part 1A of Form ADV and address: 1) additional reporting requirements with respect to Separately Managed Accounts ("SMAs"); 2) additional disclosures about investment advisers and their businesses; 3) registration on a single Form ADV of multiple fund advisers operating as a single advisory business ("Umbrella Registration"); and 4) certain clarifying and technical changes. The SEC has also proposed amendments to the Advisers Act Books and Records Rule (Rule 204-2) to require advisers to maintain additional written materials related