The Securities and Exchange Commission has adopted new disclosure requirements for Form ADV with regard to the Separately Managed Accounts business conducted by Registered Investment Advisers. The SEC took advantage of this rule-making opportunity to clarify umbrella registration procedures, to expand identification information required of investment advisory businesses and to tighten up retention rules for performance records. All of these provisions will take effect October 1, 2017.
My Compliance Office offers this 9-page paper which discusses:
- SMA disclosure requirements
- Umbrella registration
- Enhanced identification disclosure
- Performance record retention
- Preparing for the effective date
- Results from our poll
MyComplianceOffice is a global provider of powerful compliance program software. Trusted by some of the world’s most well-known financial services firms to automate and integrate multiple compliance program elements including employee personal trading, gifts and entertainment, third party and vendor risk management, trade surveillance and much more. To learn more visit: www.mycomplianceoffice.com