Annual updating amendment to form adv
This information includes the percentage of SMA regulatory assets under management across different asset categories, the use of borrowings and derivatives, and the identification of custodians that account for at least 10% of SMA regulatory assets under management.
As with the rest of Form ADV Part 1A, this information will be available to the public through the SEC’s Investment Adviser Registration Depository system. Advisers that subadvise pooled investment vehicles should not treat those accounts as SMAs for purposes of this Form ADV Part 1A, even if the adviser treats such accounts as SMAs for internal reporting purposes, as many advisers do.
Spring is a busy time for investment advisers because they are required to submit their annual update to the Securities and Exchange Commission (“SEC”).
Specifically, if a registrant does not have enough data to provide a complete response with respect to certain questions in Item 5 and the related Schedule D sections that are required to be filled out on an annual basis (e.g., Schedule D, Section 5. Advisers should note that the 2012 Guidance did not supersede prior guidance issued in 2005 relating to the registration requirements applicable to general partners or managing members of private funds, referred to by SEC staff as “special purpose vehicles.” SEC staff has confirmed that new sections of the Form do not affect the registration requirements applicable to special purpose vehicles, which are not required to complete a Schedule R, as described below.
K.(2)), the registrant may enter “0” as a placeholder in order to submit its Form ADV and note that a placeholder value of “0” was used in the Miscellaneous Section of Schedule D. Perhaps the most material amendment to the Form is a new requirement to provide aggregate information about the SMAs managed by advisers in a new section on their Form ADV filings. asks if the registrant has any regulatory assets under management attributable to SMA clients (i.e., regulatory assets under management not attributable to investment companies, business development companies, and pooled investment vehicles, as reported in Item 5. If the answer is “yes,” the registrant will be required to report on Section 5.
The amended Form updates Item 5 of Part 1A and Section 5 of Schedule D.
If a custodian holds at least 10% of an adviser’s total SMA regulatory assets under management, the registrant must complete Section 5. The revised Form ADV creates a new disclosure protocol for advisers relying on umbrella registration and codifies the registration requirements set forth in the 2012 Guidance.