March 22, 2018
Downloadable Resource for New ADV Reporting Obligation on Branch Offices
WHAT HAPPENED?
As of October 1st, 2017, the amended Form ADV requirements include a new reporting obligation for Part 1, Item 1(F) – Principal Office and Place of Business. A fifth question was added to note the total number of offices (other than your principal office and place of business) at which you conduct investment advisory business as of the end of the most recent fiscal year.
The total number of offices listed for Part 1, Item 1(F) should be reflected in Section 1(F) of Schedule D. It is required to complete Section 1(F) of Schedule D for each office (other than your principal office and place of business) at which you conduct investment advisory business. If you are registered with the SEC only, or if you are an exempt reporting advisor, only the largest 25 offices are subject to reporting.
This amendment supports the 2017 Examination Priorities for the SEC’s Office of Compliance Inspections and Examinations (OCIE).
WHAT DOES THIS MEAN FOR ME?
For your convenience, Fairview has created a downloadable resource to assist with the gathering of information required by the new ADV reporting obligation. Use the “Branch Office Checklist” for each of your branch locations.
As always, Fairview is readily available to answer any questions or concerns regarding Form ADV and the new reporting obligations.
Sources: https://www.sec.gov/rules/final/2016/ia-4509-form-adv-summary-of-changes.pdf
https://corpgov.law.harvard.edu/2017/09/23/new-disclosure-requirements-in-form-adv/
https://www.sec.gov/about/offices/ocie/national-examination-program-priorities-2017.pdf
